Prosecution Insights
Last updated: October 02, 2026
Application No. 18/424,211

BATTERY PACK ENCLOSURE

Non-Final OA §102§103
Filed
Jan 26, 2024
Priority
Jan 31, 2023 — provisional 63/442,192
Examiner
VO, JIMMY
Art Unit
Tech Center
Assignee
Cummins Inc.
OA Round
1 (Non-Final)
74%
Grant Probability
Favorable
1-2
OA Rounds
3m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allowance Rate
511 granted / 694 resolved
+13.6% vs TC avg
Strong +22% interview lift
Without
With
+21.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
42 currently pending
Career history
724
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
59.9%
+19.9% vs TC avg
§102
21.7%
-18.3% vs TC avg
§112
13.4%
-26.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 694 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 Group I (Claims 1-19) in the reply filed on 7/30/2026 is acknowledged. Information Disclosure Statement The information disclosure statement (IDS) submitted on 1/26/2024 was filed. The submission is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement has been considered by the examiner. Drawings The drawings were received on 1/26/24. These drawings are acceptable. Specification The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed. 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, 4-6, 8, 9, and 14 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by US 2011/0293982 A1 (US’982). As to Claim 1: US’982 discloses a battery pack enclosure comprising a battery pack assembly 10 having a plurality of cooling modules 18, battery cells 100, end plates 12, and tension-rod assemblies 14 maintained in a stacked arrangement (US’982, [0025], [0034]); a top panel and a bottom panel, wherein US’982 teaches that an end plate 12 may be provided on both ends of the battery pack assembly and further describes the plural end plates 12 positioned at the respective ends of the assembly (US’982, [0025], [0028], [0034]); a plurality of surround frames, each surround frame arranged to support a plurality of battery cells, wherein each cooling module 18 includes a frame 20 having first, second, third, and fourth legs 26, 28, 30, and 32 forming a generally rectangular opening 34 through the central portion of the frame, a pair of battery cells 100 is disposed between adjacent cooling modules 18, and wall sections 50 of the frames retain the battery cells between adjacent frames (US’982, [0025]-[0026], [0028]); wherein the surround frames are stacked, as evidenced by the cooling modules 18, including their respective frames 20, being arranged in stacked relation, with the wall sections 50 of one frame abutting the adjacent frame to align the repeating frames in the stacked relation (US’982, [0025], [0028], [0034]); and a seal provided between two adjacent surround frames, wherein first and second seal members 42, 44 are disposed adjacent the outer peripheral edge of each frame 20 and form a substantially fluid-tight seal around at least a portion of the peripheral edge of adjacent frames, and compression of the stacked assembly causes the seal members to abut the adjacent frame and form the substantially fluid-tight seal therebetween (US’982, [0027], [0034]). As to Claim 4: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above; and further discloses a plurality of fasteners arranged to urge two adjacent surround frames together, wherein a plurality of tension-rod assemblies 14 extends from one end of the battery pack assembly 10 to the opposite end and holds the cooling modules 18, battery cells 100, and end plates 12 under compression in their stacked relation (US’982, [0025]). Each frame 20 includes tabs 36 having apertures 38 that receive the tension-rod assemblies 14 to hold the cooling modules, battery cells, and end plates under compression (US’982, [0026]). The tension-rod assemblies 14 are inserted through the frame apertures and coupled to the battery pack assembly to apply a compressive force, causing the seal members 42, 44 of each frame 20 to abut the adjacent frame and thereby urging the adjacent surround frames together (US’982, [0034]). As to Claim 5: US’982 discloses the battery pack enclosure of claim 4, as set forth in the rejections of claims 1 and 4 above; and further discloses that a fastener is provided at each corner of the battery pack enclosure, wherein tabs 36 are formed adjacent each corner of every frame 20, an aperture 38 is formed in each tab 36, and the apertures receive the tension-rod assemblies 14 that hold the cooling modules 18, battery cells 100, and end plates 12 under compression in the stacked relation (US’982, [0026]). The plurality of tension-rod assemblies 14 extends from one end of the battery pack assembly 10 to the opposite end and maintains the stacked battery-pack components under compression, thereby providing a respective tension-rod fastener at each corner of the battery pack enclosure (US’982, [0025], [0034]). As to Claim 6: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above; and further discloses that two adjacent surround frames are connected without the use of multiple peripheral fasteners, wherein wall sections 50 of one frame 20 abut the second side 24 of an adjacent frame 20 and align the repeating frames in their stacked relation (US’982, [0028]). Seal members 42, 44 are positioned around the peripheral edge of each frame and form a substantially fluid-tight seal between the adjacent frames without individual peripheral fasteners fastening the two frames together at their interface (US’982, [0027]). Instead, tension-rod assemblies 14 extend from one end of the entire battery pack assembly 10 to the opposite end and apply a compressive force to the overall stack, causing the seal members of each frame to abut the adjacent frame and connect and seal the adjacent frames in the stacked assembly (US’982, [0025], [0034]). As to Claim 8: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above; and further discloses that each surround frame is at least partially open on two sides, wherein each frame 20 includes first, second, third, and fourth legs 26, 28, 30, and 32 surrounding an opening 34 through the central portion of the frame (US’982, [0026]). US’982 further discloses a plurality of slots 52 formed through the first leg 26 and the second leg 28 of each frame 20, such that the frame is at least partially open through two respective sides and the slots provide fluid communication through those two sides to the cooling fin 60 (US’982, [0029], [0031]). As to Claim 9: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above; and further discloses that each surround frame comprises a plurality of walls, wherein frame 220 includes first, second, third, and fourth legs 226, 228, 230, and 232 surrounding an opening 234 through the central portion of the frame (US’982, [0037]). US’982 further discloses that each wall comprises a top lip and a bottom lip, wherein a channel 252 is formed in each of the four legs 226, 228, 230, and 232, and the channel includes a pair of coextensive, spaced-apart lips 254 and 255 that engage opposing outer surfaces of cooling fin 260 (US’982, [0040]). Thus, the first and second spaced-apart lips 254, 255 respectively correspond to the claimed top and bottom lips of each surround-frame wall (US’982, [0037], [0040]). As to Claim 14: US’982 discloses a battery pack comprising a battery pack assembly 10 having a plurality of battery cells 100 and cooling modules 18 arranged in a stacked relation (US’982, [0025], [0034]); a plurality of battery cells arranged in tiers, wherein a pair of battery cells 100 is disposed between each pair of successive cooling modules 18, thereby providing repeated tiers of battery cells within the stacked battery pack assembly (US’982, [0025], [0034]); and a battery pack enclosure, wherein the stacked cooling-module frames 20, end plates 12, seal members 42, 44, and tension-rod assemblies 14 collectively surround, retain, seal, and compress the battery cells within the battery pack assembly (US’982, [0025]-[0028], [0034]); wherein the battery pack enclosure comprises a top panel and a bottom panel, corresponding to the end plates 12 provided on both respective ends of the battery pack assembly (US’982, [0025], [0028], [0034]); and a plurality of surround frames, wherein each cooling module 18 includes a frame 20 having first, second, third, and fourth legs 26, 28, 30, and 32 forming a generally rectangular opening 34 through the central portion of the frame (US’982, [0025]-[0026]); each surround frame supporting a tier of battery cells, wherein a pair of battery cells 100 is disposed between successive cooling-module frames 20, wall sections 50 of the frames retain the battery cells between adjacent frames, and the cooling fins 60 associated with the frames contact and secure the battery cells between successive cooling modules (US’982, [0025], [0028], [0034]); wherein the surround frames are stacked, as evidenced by the cooling modules 18, including their respective frames 20, being placed in stacked relation, with the wall sections 50 of each frame abutting an adjacent frame and aligning the repeating frames in the stack (US’982, [0025], [0028], [0034]); and a seal provided between two adjacent surround frames, wherein seal members 42, 44 are disposed adjacent the outer peripheral edge of each frame 20 and form a substantially fluid-tight seal around at least a portion of the peripheral edge of adjacent frames, and compression of the assembly causes the seal members to abut the adjacent frames and form the seal therebetween (US’982, [0027], [0034]). 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. 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. Claims 2-3 are rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (US’982), as applied to Claim 1, and further in view of US 5,516,581 (US’581). As to Claim 2: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above. US’982 further discloses first and second seal members 42, 44 disposed adjacent the outer peripheral edge of each frame 20 to form a substantially fluid-tight seal around at least a portion of the peripheral edge of adjacent frames (US’982, [0027]). US’982 teaches that the seal members may be formed from material dispensed onto the frame or may be performed from a gasket material and that an adhesive may be employed to couple the seal members to the frame (US’982, [0027]). Compression of the stacked assembly causes the seal members to abut the adjacent frames and form a substantially fluid-tight seal therebetween (US’982, [0034]). However, US’982 does not expressly disclose that the seal comprises a pressure-sensitive adhesive. US’581 discloses a removable adhesive tape comprising a backing bearing a layer of pressure-sensitive adhesive on at least one major surface. The pressure-sensitive adhesive tape becomes firmly bonded to a substrate and can subsequently be removed without damaging the substrate by stretching the tape substantially parallel to the substrate surface (US’581, Pgs. 2-3). US’581 further teaches double-coated tape having pressure-sensitive adhesive layers on both major surfaces for mounting and joining two surfaces (US’581, Pg. 3). The pressure-sensitive adhesive may be selected to provide sufficient shear strength and adhesive holding power for the intended application, and suitable pressure-sensitive adhesives include tackifier rubber, silicone, polyurethane, block-copolymer, and acrylic adhesives (US’581, Pg. 5). US’581 also expressly teaches use of its pressure-sensitive adhesive tapes for joining articles and providing removable container closures and seals (US’581, Pgs. 6, 8-9). US’982 and US’581 are analogous arts because both references concern adhesive structures used to join or seal adjacent surfaces. US’982 expressly contemplates using an adhesive to couple a seal member to the peripheral frame surface of a battery pack (US’982, [0027]), while US’581 concerns pressure-sensitive adhesive materials for firmly joining surfaces and forming closures or seals, including double-coated adhesive constructions positioned between two surfaces (US’581, Pgs. 2-3, 6, 8-9). Thus, US’581 is reasonably pertinent to the adhesive-seal selection expressly contemplated by US’982. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form or provide the seal members 42, 44 of US’982 using the pressure-sensitive adhesive tape taught by US’581, including a double-coated pressure-sensitive adhesive construction positioned between adjacent frame surfaces, because US’581 teaches that such an adhesive provides sufficient holding power to firmly join two surfaces while also permitting clean removal without adhesive residue or damage when separation is desired (US’581, Pgs. 2-3, 5, 8). The resulting battery pack enclosure would therefore include a seal comprising a pressure-sensitive adhesive, as required by claim 2. As to Claim 3: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above. US’982 further discloses seal members 42, 44 disposed adjacent the outer peripheral edge of each frame 20 and forming a substantially fluid-tight seal around at least a portion of the peripheral edge of adjacent stacked frames (US’982, [0027]). US’982 teaches that the seal members may be formed from material dispensed onto the frame or may be preformed from gasket material and coupled to the frame with an adhesive (US’982, [0027]). Tension-rod assemblies 14 extend through apertures in the frames and maintain the cooling modules 18, battery cells 100, and end plates 12 under compression in their stacked relation (US’982, [0025]-[0026], [0034]). However, US’982 does not expressly disclose that the seal is removable while the surround frames are stacked. US’581 discloses a pressure-sensitive adhesive tape that becomes firmly bonded to a substrate but can be removed without damaging the substrate by stretching the tape substantially parallel to the substrate surface (US’581, Pgs. 2-3). US’581 teaches that the tape may be double-coated, with pressure-sensitive adhesive layers on both major surfaces, for mounting and joining two surfaces (US’581, Pg. 3). Removal by stretching leaves no appreciable adhesive residue and avoids damage to the bonded surfaces (US’581, Pgs. 3, 6). US’581 also provides an adhesive-free tab that remains available for grasping and pulling the tape from between bonded surfaces (US’581, Pg. 7). In a joining application, the double-coated pressure-sensitive adhesive tape securely joins two articles and is subsequently removed by pulling the exposed tab to stretch the tape and release the joined surfaces (US’581, Pg. 8). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form or provide the seal members 42, 44 of US’982 using the removable pressure-sensitive adhesive tape of US’581, with an adhesive-free pull tab extending to an accessible location, because US’581 teaches that the tape firmly joins two surfaces during use and can subsequently be removed cleanly by pulling and stretching the tape substantially parallel to those surfaces (US’581, Pgs. 2-3, 7-8). Because the tension-rod assemblies 14 of US’982 independently retain the frames under compression in their stacked relation, the modified adhesive seal could be withdrawn by its pull tab while the surround frames remain stacked (US’982, [0025]-[0026], [0034]). The resulting battery pack enclosure would therefore have a seal removable while the surround frames are stacked, as required by claim 3. Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (US’982), as applied to Claim 1, and further in view of US 2012/0223113 A1 (US’113). As to Claim 7: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above. In particular, US’982 discloses a plurality of cooling modules 18 arranged in stacked relation, wherein each cooling module includes a surround frame 20 supporting battery cells 100 positioned between adjacent cooling modules (US’982, [0025]). Each frame 20 includes first, second, third, and fourth legs 26, 28, 30, and 32 forming a generally rectangular opening 34 through the central portion of the frame (US’982, [0026]). Wall sections 50 retain the battery cells between adjacent frames and align the repeating frames in their stacked relation (US’982, [0028]). However, US’982 does not disclose that the surround frames are formed from single continuous bent extrusions. Instead, US’982 states that frame 20 may be formed as a unitary frame by injection molding nylon, polypropylene, metal, or another suitable material (US’982, [0026]). US’113 discloses a peripheral frame 10 for a vehicle battery tray, wherein the frame defines a battery housing together with a floor and roof (US’113, [0014]-[0017], [0095]-[0097]). US’113 teaches that the frame profile preferably comprises at least one bent portion and is made in one piece as a single unit obtained by extrusion, with its first and second ends fixed together (US’113, [0029]-[0032]). More particularly, profile 10a constitutes a single unit obtained from extrusion and is bent after extrusion into an annular closed shape. The resulting frame has two longitudinal portions, two lateral portions, and four intermediate bent portions connecting the longitudinal and lateral portions, thereby forming a substantially rectangular continuous frame (US’113, [0097]-[0099]). US’113 similarly discloses a second peripheral profile 10b formed as a single unit that is bent into a closed, substantially rectangular shape (US’113, [0108]-[0109]). US’982 and US’113 are analogous arts because both references concern structural frames and enclosures for supporting and protecting batteries, particularly batteries used in vehicles. US’982 concerns repeating frames that support and retain battery cells in a battery pack (US’982, [0001], [0025]-[0028]), while US’113 concerns a peripheral battery-tray frame that defines a housing for vehicle batteries (US’113, [0001]-[0002], [0014]-[0017]). Thus, US’113 is reasonably pertinent to the construction and manufacture of the battery-supporting surround frames disclosed by US’982. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form each surround frame 20 of US’982 from a single continuous extruded profile that is bent into a closed, substantially rectangular shape and whose ends are fixed together, as taught by US’113. US’113 expressly teaches that forming the frame from a bent, single-piece extrusion requires fewer manufacturing operations, provides flexibility in the manufacturing process, increases frame strength, and reduces manufacturing cost (US’113, [0017], [0029]-[0032]). The resulting battery pack enclosure would therefore have surround frames formed from single continuous bent extrusions, as required by claim 7. Claims 10, 11, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (US’982), as applied to Claim 1, and further in view of US 2016/0002909 A1 (US’909). As to Claim 10: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above. In particular, US’982 discloses a plurality of cooling modules 18 arranged in stacked relation, wherein each cooling module includes a generally rectangular surround frame 20 supporting battery cells 100 between adjacent frames (US’982, [0025]-[0026]). Tabs 36 are formed adjacent each corner of frame 20, and each tab includes an aperture 38 for receiving a tension-rod assembly 14 that holds the cooling modules, battery cells, and end plates under compression (US’982, [0026]). Wall sections 50 formed adjacent the corners retain the battery cells and align the repeating frames in the stacked relation (US’982, [0028]). However, US’982 does not expressly disclose that the surround frames comprise corner gussets. US’909 discloses modular surround-frame structures having upper and lower connectors positioned at the upper and lower corners of the respective modular frames, with a gusset plate 30 sandwiched between the corner connectors (US’909, [0128]-[0130], [0134]). The gusset plate includes through-holes aligned with apertures in the upper and lower corner connectors so that bolts or screws fasten the connectors and gusset plate together (US’909, [0134], [0137]). US’909 further teaches that the gusset plate may be sized for one or more columns and may join two, three, four, or more modules at their corners (US’909, [0145]-[0146]). When assembled, tension bolts pull the upper and lower frame tubes and the gusset plate together to establish a continuous moment-resisting connection and reduce racking of the connected frames (US’909, [0152]-[0153]). The gusset plates also provide locating features that align stacked modules and maintain the geometry of the module stack (US’909, [0080], [0145], [0228]). US’982 and US’909 are analogous arts because both references concern stacked structural frames having corner connections used to align the frames and transmit forces through the stacked assembly. US’982 uses corner tabs, apertures, and tension rods to align and compress repeating battery-pack frames (US’982, [0025]-[0026], [0028], [0034]), while US’909 uses corner connectors, gusset plates, and bolts to align stacked frames, connect adjacent frame units, transmit loads, and reduce racking (US’909, [0074]-[0080], [0145], [0152]-[0153]). Thus, US’909 is reasonably pertinent to reinforcing and aligning the corner regions of the stacked frames disclosed by US’982. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide the corner regions of each surround frame 20 of US’982 with gusset plates as taught by US’909, positioned in association with the existing corner tabs 36 and tension-rod apertures 38. US’909 expressly teaches that corner gusset plates provide aligned fastening locations, maintain the geometry of stacked frames, transmit forces through the corner connections, and reduce racking of the connected frames (US’909, [0080], [0134], [0145], [0152]-[0153]). The resulting battery pack enclosure would therefore have surround frames comprising corner gussets, as required by claim 10. As to Claim 11: US’982 discloses the battery pack enclosure of claim 10, as set forth in the rejection of claim 10 above. US’982 further discloses tabs 36 positioned adjacent each corner of every surround frame 20, wherein each tab 36 includes an aperture 38 arranged to receive a tension-rod assembly 14 (US’982, [0026]). The tension-rod assemblies extend from one end of the battery pack assembly to the opposite end and apply a compressive force that holds the cooling-module frames 20 in their stacked relation, thereby fastening adjacent surround frames together (US’982, [0025]-[0026], [0034]). However, although US’982 discloses corner tabs having apertures that receive fasteners, US’982 does not expressly disclose corner gussets arranged to receive the fasteners that fasten two adjacent surround frames together. US’909 discloses corner gusset plates 30 positioned between upper and lower corner connectors of adjacent modular frames (US’909, [0128]-[0130]). Each gusset plate 30 includes through-holes 31 aligned with apertures 12 in the upper and lower corner connectors, thereby allowing bolts or screws to pass through the gusset plate and fasten the connectors together (US’909, [0134]). Tension bolts 25 pass through the gusset plate 30 to secure vertically adjacent modules and provide a continuous structural connection between the stacked frames (US’909, [0137]). US’909 further discloses flathead screws 34 passing through holes 32 in the gusset plate to accurately unite adjacent columns and their respective modular frames (US’909, [0145]). The tension bolts trap and clamp the gusset plate between adjacent frame connectors and pull the upper and lower frame tubes and gusset plate together (US’909, [0152]-[0153]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide the corner regions of the surround frames 20 of US’982 with the apertured gusset plates taught by US’909 and to align the gusset-plate holes with the existing corner apertures so that the tension-rod fasteners pass through the gussets and fasten adjacent surround frames together. US’909 expressly teaches that this arrangement accurately aligns and unites adjacent frames, transfers loads through the corner connection, establishes a continuous structural connection, and reduces racking (US’909, [0134], [0137], [0145], [0152]-[0153]). The resulting battery pack enclosure would therefore include corner gussets arranged to receive fasteners that fasten two adjacent surround frames together, as required by claim 11. As to Claim 16: US’982 discloses the battery pack of claim 14, as set forth in the rejection of claim 14 above. In particular, US’982 discloses a plurality of battery cells 100 arranged in tiers between successive cooling modules 18, wherein each cooling module includes a generally rectangular surround frame 20 having first, second, third, and fourth legs 26, 28, 30, and 32 (US’982, [0025]-[0026], [0034]). The surround frames 20 are arranged in stacked relation, and seal members 42, 44 form substantially fluid-tight seals between adjacent surround frames (US’982, [0027]-[0028], [0034]). Tension-rod assemblies 14 extend through corner apertures in the frames and apply a compressive force to the stacked battery-pack assembly (US’982, [0025]-[0026], [0034]). However, US’982 does not expressly disclose at least one cross member running between two walls of each surround frame and at least one fastener that fastens the cross members of adjacent tiers. The tension-rod assemblies of US’982 extend through corner tabs of the frames rather than fastening corresponding cross members of adjacent tiers. US’909 discloses modular surround frames having floor and ceiling frames constructed from longitudinal and lateral perimeter beams together with internal infill members. The perimeter beams define the surrounding walls of each frame, while the infill members extend within the perimeter frame and correspond to cross members running between opposed frame walls (US’909, [0148]-[0149]). The floor frame and ceiling frame are connected by corner columns to form the complete modular surround frame (US’909, [0155]). US’909 further discloses vertically stacked frames and expressly teaches joining an open-topped lower frame to an open-bottomed upper frame using bolts passing through the horizontal frame members of the two stacked frames (US’909, [0120], [0176]). US’909 additionally teaches tension bolts 25 that pull the upper and lower frame tubes together, establish a continuous structural connection, transfer loads through the connection, and It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide each surround frame 20 of US’982 with at least one transverse infill member extending between two opposed frame legs or walls, as taught by US’909, and to align and fasten the corresponding cross members of adjacent battery-cell tiers using bolts passing through the horizontal frame members. US’909 expressly teaches that bolting the horizontal members of adjacent stacked frames together provides a continuous structural connection, transfers loads through the connection, and reduces racking of the stacked frames (US’909, [0152]-[0153], [0176]). The resulting battery pack would therefore include at least one cross member running between two walls of each surround frame and at least one fastener fastening the cross members of adjacent tiers, as required by claim 16. Claims 12 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (US’982), as applied to Claim 1, and further in view of US 2020/0091571 A1 (US’571). As to Claim 12: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above. In particular, US’982 discloses a plurality of cooling modules 18 arranged in stacked relation, wherein each cooling module includes a generally rectangular surround frame 20 supporting a plurality of battery cells 100 between adjacent cooling modules (US’982, [0025]-[0026], [0034]). Wall sections 50 retain the battery cells between adjacent frames, and the cooling fins 60 associated with the frames contact and secure the battery cells in the stacked assembly (US’982, [0028], [0034]). However, US’982 does not expressly disclose that each surround frame comprises a plurality of cell-support rails on which the battery cells can be mounted. US’571 discloses battery modules 4, each containing approximately 15 to 25 battery cells 2 retained within a module frame 6 (US’571, [0007]-[0009]). Corner bolts in the module end frames fix each multi-cell battery module onto support rails, and those support rails contribute to the structural strength of the battery enclosure and protect the battery during vehicle use and misuse (US’571, [0010]). Mounting the module on the support rails maintains the bottom surfaces of the individual cells in alignment for contact with a battery cooler (US’571, [0009]-[0011]). US’571 further discloses module side rails to which the battery cooler may be mechanically connected, including arrangements employing threaded studs or features that permit fixation by sliding the cooler onto the module-support rail (US’571, [0057]). Thus, US’571 teaches a plurality of enclosure-support rails on which a module containing a plurality of battery cells is mounted, thereby mounting and supporting the cells through their module frame. US’982 and US’571 are analogous arts because both references concern structural frames and cooling architectures for supporting battery cells in vehicle battery enclosures. US’982 employs repeating surround frames and cooling fins to retain, support, and cool battery cells in a stacked battery pack (US’982, [0001], [0025]-[0035]), while US’571 employs battery-enclosure support rails, module frames, and cooling structures to support battery cells, maintain cell alignment, and provide thermal contact with a cooler (US’571, [0002], [0009]-[0011]). Thus, US’571 is reasonably pertinent to the physical support and mounting of battery cells within the surround frames of US’982. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide each surround frame 20 of US’982 with a plurality of cell-support rails, as taught by US’571, and to mount the battery cells on those rails through their supporting module or cell frame. US’571 expressly teaches that mounting multi-cell battery modules on support rails maintains cell alignment, contributes to battery-enclosure structural strength, protects the battery during vehicle operation, and presents aligned cell surfaces for thermal contact with a battery cooler (US’571, [0009]-[0011]). The resulting battery pack enclosure would therefore have each surround frame comprising a plurality of cell-support rails on which the battery cells can be mounted, as required by claim 12. As to Claim 15: US’982 discloses the battery pack of claim 14, as set forth in the rejection of claim 14 above. In particular, US’982 discloses a plurality of battery cells 100 arranged in tiers between successive cooling modules 18, wherein each cooling module includes a generally rectangular surround frame 20 (US’982, [0025]-[0026], [0034]). The frames 20 are stacked, wall sections 50 retain the battery cells between adjacent frames, and cooling fins 60 associated with the frames contact and secure the battery cells in the stacked battery pack (US’982, [0028], [0034]). However, US’982 does not expressly disclose that each surround frame comprises a plurality of cell-support rails and that the battery cells are mounted on the cell-support rails. US’571 discloses battery modules 4, each containing approximately 15 to 25 battery cells 2 retained within a module frame 6 (US’571, [0007]-[0009]). Corner bolts in the module end frames fix the multi-cell battery module onto a plurality of support rails, and the support rails contribute to the structural strength of the battery enclosure and protect the battery during vehicle operation and misuse (US’571, [0010]). Because the battery cells are retained within the module frame and the module frame is fixed to the support rails, the battery cells are mounted on and supported by the rails through the module frame (US’571, [0009]-[0010]). When the module is mounted in the battery architecture, the rail-supported module maintains one surface of each cell in alignment with the other cells for contact with the battery cooler (US’571, [0011]). US’571 further discloses module-side rails and mechanical connections employing threaded studs or features that permit fixation by sliding a component onto the module-support rail (US’571, [0057]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide each tier-supporting surround frame 20 of US’982 with a plurality of cell-support rails and to mount the battery cells on those rails through their supporting module or cell frame, as taught by US’571. US’571 expressly teaches that mounting multi-cell battery modules on support rails maintains alignment of the individual cells, contributes to battery-enclosure structural strength, protects the battery during vehicle operation, and positions the cells for thermal contact with a battery cooler (US’571, [0009]-[0011]). The resulting battery pack would therefore have each surround frame comprising a plurality of cell-support rails with the battery cells mounted on those rails, as required by claim 15. Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (US’982), as applied to Claim 1, and further in view of US 2020/0156486 A1 (US’486). As to Claim 13: US’982 discloses the battery pack enclosure of claim 1, as set forth in the rejection of claim 1 above. In particular, US’982 discloses a battery pack assembly 10 having end plates 12 positioned on both ends of a stack of generally rectangular surround frames 20, wherein the end plates correspond to the claimed top and bottom panels (US’982, [0025]-[0026], [0034]). US’982 further discloses that seal members 42, 44 may be disposed between an end plate 12 and an adjacent frame 20 and that an adhesive may be used to couple the seal members to the frame (US’982, [0027]). However, although US’982 discloses adhesive attachment of seal members to the surround frames, US’982 does not expressly disclose that the top panel and the bottom panel themselves are attached to the surround frames with adhesive. US’486 discloses a battery enclosure having a lid 400 corresponding to a top panel, a base plate 100 corresponding to a bottom panel, and a surrounding battery tray 300 and external support structure 200 corresponding to a surround frame (US’486, [0021], [0038], [0040], [0047], [0057], [0065]). US’486 expressly teaches that adhesives may be applied along the engaging surfaces of the lid 400, battery tray 300, external support structure 200, and base plate 100, thereby adhesively attaching the upper lid to the surrounding structure (US’486, [0045]). US’486 further teaches that the base plate 100 and external support structure 200 are joined along the enclosure periphery and may be coupled using chemical adhesive bonding, thereby adhesively attaching the bottom panel to the surrounding frame structure (US’486, [0069]). US’486 also teaches a bonded seal around the lid perimeter to form a leak-tight union with the underlying battery tray (US’486, [0040], [0043]). US’982 and US’486 are analogous arts because both references concern battery-pack enclosures having peripheral frame structures, upper and lower enclosure panels, and sealing arrangements that protect enclosed battery cells. US’982 uses repeating frames, end plates, and seals to form a substantially fluid-tight battery-pack assembly (US’982, [0025]-[0028], [0034]), while US’486 uses a lid, base plate, battery tray, external peripheral support structure, adhesive bonds, and seals to form an environmentally sealed battery enclosure (US’486, [0006]-[0019], [0021]-[0025], [0040]-[0045], [0069]-[0071]). Thus, US’486 is reasonably pertinent to attaching and sealing the top and bottom panels of the battery-pack enclosure disclosed by US’982. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to adhesively attach the end plates 12 forming the top and bottom panels of US’982 to the terminal surround frames 20, as taught by US’486, by applying adhesive along the engaging panel-and-frame surfaces. US’486 expressly teaches adhesive bonding between its lid, battery tray, external support structure, and base plate and teaches that the associated seals form a leak-tight, environmentally sealed battery enclosure that inhibits fluid ingress and egress (US’486, [0006]-[0019], [0043], [0045], [0069]-[0071]). The resulting battery pack enclosure would therefore have its top panel and bottom panel attached to the surround frames with adhesive, as required by claim 13. Claims 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (US’982) in view of US 2017/0279172 A1 (US’172). As to Claim 17: US’982 discloses the battery pack of claim 14, as set forth in the rejection of claim 14 above. In particular, US’982 discloses tiers of battery cells 100 positioned between successive stacked surround frames 20 and enclosed between end plates 12 (US’982, [0025]-[0028], [0034]). Each battery cell 100 includes first and second electrically conductive tabs 102, 104, and US’982 teaches that the conductive tabs may be placed in electrical communication with one another and with an associated electrical device using a wiring harness, electrical connectors, or similar structures (US’982, [0025]). However, US’982 does not expressly disclose that the battery cells in one tier are electrically connected to the battery cells in another tier inside the battery pack enclosure. US’172 discloses stackable battery modules, each containing a plurality of battery cells enclosed in a respective module case, wherein the module cases interlock to form a battery block or battery pack (US’172, [0004], [0020]-[0023], [0026]-[0028]). A first electrode 116 is positioned at the top of each module and electrically connected by conductive straps 118 to first terminals of the battery cells within that module (US’172, [0030]). A second electrode 122 is positioned at the bottom of each module and electrically connected to second terminals of the battery cells within that module (US’172, [0031]). When two battery modules are stacked, electrode 116 of the lower module contacts electrode 122 of the upper module, thereby electrically coupling the battery cells of the lower module to the battery cells of the upper module (US’172, [0031]). US’172 further teaches that mating the stacked module cases forms both a mechanical connection and a solid electrical interconnection between the respective modules (US’172, [0023], [0033]-[0034]). When the modules and associated connection structures are assembled, all high-voltage components are fully enclosed within the resulting battery pack (US’172, [0019], [0021], [0046]). US’982 and US’172 are analogous arts because both references concern stacked battery-cell structures that form cooled battery packs for vehicles. US’982 employs stacked frames and cooling fins to retain and cool tiers of battery cells (US’982, [0001], [0025]-[0035]), while US’172 employs stacked and interlocking battery modules containing multiple battery cells, with electrical connections formed between vertically adjacent modules to produce a complete battery pack (US’172, [0001]-[0004], [0019]-[0023], [0031]-[0034]). Thus, US’172 is reasonably pertinent to electrically interconnecting the stacked battery-cell tiers disclosed by US’982. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide each battery-cell tier of US’982 with upper and lower electrodes electrically connected to the cell terminals and to arrange the electrodes of adjacent tiers to contact one another when the tiers are stacked, as taught by US’172. US’172 expressly teaches that this arrangement simultaneously forms the stacked battery pack and electrically connects the cells of vertically adjacent modules while keeping the high-voltage components fully enclosed (US’172, [0019], [0023], [0030]-[0034], [0046]). The resulting battery pack would therefore have the battery cells in one tier electrically connected to the battery cells in another tier inside the battery pack enclosure, as required by claim 17. As to Claim 18: US’982 discloses the battery pack of claim 17, as set forth in the rejection of claim 17. In particular, US’982 discloses a battery pack assembly comprising a plurality of battery cells arranged in tiers between successive stacked cooling modules, each cooling module including a surround frame that supports and retains the battery cells. The frames and battery-cell tiers are stacked between end plates, with sealing members provided between adjacent frames (US’982, [0025]–[0028], [0034]). US’982 further discloses that each battery cell includes first and second electrically conductive tabs and that the conductive tabs may be placed in electrical communication with one another using a wiring harness, electrical connectors, or the like (US’982, [0025]). However, US’982 does not expressly disclose a positive terminal for the battery pack provided in one tier and a negative terminal for the battery pack provided in another tier. US’172 discloses a modular battery pack in which battery modules are stacked in multiple tiers or levels and electrically connected to form one or more columns. Stacking the modules forms both a mechanical connection and an electrical connection between the modules (US’172, [0023]). Each module includes an upper electrode 116 connected to a first terminal of the battery cells and a lower electrode 122 connected to a second terminal of the battery cells. When the modules are stacked, the upper electrode of a lower module contacts the lower electrode of an upper module, thereby electrically coupling the battery cells of the modules in different tiers (US’172, [0030]–[0031], [0033]–[0034]). US’172 further discloses a battery pack 300 having stacked battery modules 302, battery connection caps 306, and cross-over hats 308 (US’172, [0043]–[0044]). The cross-over hats electrically connect respective columns of battery modules in series and may connect the modules at either the top or the bottom of the columns. The orientations of the modules and the arrows shown in Figure 15 identify the resulting series-current path through the battery pack (US’172, [0045]–[0046]). The battery connection caps 306 include electrodes for electrically connecting the series-connected battery pack to a vehicle, prime mover, or other electrical system and therefore constitute the external positive and negative terminals at the respective ends of the series-current path (US’172, [0046]). Because US’172 provides electrical connection locations on both the upper and lower sides of the modules and connects columns at either the top or bottom, the respective terminal connection caps may be positioned at exposed endpoints associated with different stacked module tiers (US’172, [0030]–[0031], [0045]–[0046]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to configure the electrically connected battery-cell tiers of US’982 such that a positive battery-pack terminal is provided in one tier and a negative battery-pack terminal is provided in another tier, using the upper and lower electrode and connection-cap arrangement taught by US’172. US’172 expressly teaches arranging modular battery units into customizable series-connected configurations, providing electrical connections at the top or bottom of the stacked modules, and using terminal connection caps at the endpoints of the series-current path. Applying that arrangement to US’982 would permit the terminal locations to be selected among different tiers to accommodate the desired battery-pack shape, available installation space, and external electrical connection while maintaining the high-voltage connections within the assembled battery-pack structure (US’172, [0019]–[0024], [0043]–[0046]). Claim 19 is rejected under 35 U.S.C. 103 as being unpatentable over US 2011/0293982 A1 (“US’982”), as applied to Claim 1, and further in view of US 9,893,385 B1 (“US’385”). As to Claim 19: US’982 discloses the battery pack of claim 14, as set forth in the rejection of claim 14. In particular, US’982 discloses a battery pack assembly comprising a plurality of battery cells arranged in repeating, stacked tiers between adjacent cooling modules; each cooling module includes a frame supporting and retaining the battery cells; the frames are stacked between end plates; and sealing members form substantially fluid-tight seals between adjacent frames and between the frames and end plates (US’982, [0025]–[0028], [0034]). However, US’982 does not expressly disclose that each tier comprises a low-voltage component and that a low-voltage component in one tier is electrically connected to a low-voltage component in another tier inside the battery-pack enclosure. US’385 discloses a battery-management system comprising multiple electrical circuit boards distributed throughout a battery core, including one circuit board connected to each cell pack. Each circuit board is connected to and controls its own set of cells, cell modules, or cell packs and communicates information to another circuit board or to a coordinating circuit board (US’385, Pg. 18). US’385 further discloses that the components and integrated circuits of each BMS controller board are powered at low-voltage levels, including 12 VDC, 5 VDC, and 3.3 VDC, with these voltages routed to components on the board (US’385, Pgs. 18–19). US’385 also expressly teaches a distributed BMS topology in which a battery-controller board is installed at each cell, module, pack, or other group of cells, with communication cables connecting the multiple battery-controller boards to one another and/or to a higher-order master controller (US’385, Pg. 26). The BMS controller boards may be positioned within cells, modules, packs, cores, systems, or batteries, and pack controllers communicate with one another through pack-to-pack communication wires (US’385, Pg. 29). Thus, US’385 teaches low-voltage BMS components associated with respective groups or tiers of battery cells and electrically connected across those groups within the battery system. US’982 and US’385 are analogous art because both concern multi-cell battery assemblies and systems. US’982 concerns the physical organization and enclosure of battery cells in a stacked battery pack (US’982, [0001]–[0004], [0025]), while US’385 concerns monitoring and regulating cells, modules, and packs within an energy-storage battery system using distributed battery-controller boards (US’385, Pgs. 2, 18, 26). The references therefore address the same field of battery-pack construction and operation. It would have been obvious to a person skilled in the art before the effective filing date of the instant application to provide each battery-cell tier of US’982 with a low-voltage BMS controller board and to electrically connect the controller board in one tier to the controller board in another tier, within the battery-pack enclosure, as taught by US’385, so that each board controls its associated cells while communicating information to other boards or a coordinating controller. US’385 expressly identifies this distributed topology—having a controller board at each cell, module, pack, or other cell group—as simple to install and providing a clean assembly (US’385, Pg. 26). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 20220102781 A1 discloses a battery cell system includes a plurality of battery cells having an annular shape abutting one another to form a battery cell stack with an annular shape to facilitate cooling. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JIMMY K VO whose telephone number is (571)272-3242. The examiner can normally be reached Monday - Friday, 8 am to 6 pm 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, Tong Guo can be reached at (571) 272-3066. 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. /JIMMY VO/ Primary Examiner Art Unit 1723 /JIMMY VO/ Primary Examiner, Art Unit 1723
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Prosecution Timeline

Jan 26, 2024
Application Filed
Aug 19, 2026
Non-Final Rejection mailed — §102, §103 (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
74%
Grant Probability
96%
With Interview (+21.9%)
2y 11m (~3m remaining)
Median Time to Grant
Low
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