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 .
Remarks
2. Applicant’s amendments submitted on 6/29/26 have been received. Claims 10 and 13 have been amended. Claims 17-19 have been cancelled. Claims 20-23 are new.
Claim Objections
3. The objection to claim 18 is withdrawn because the Applicant cancelled the claim.
Claim Rejections - 35 USC § 102
4. 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.
5. 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)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
6. Claim(s) 1, 2, 4-7, 12, 14, and 15 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Jang et al. (US 2024/0413479).
Regarding claim 1, Jang discloses a traction battery pack assembly(abstract, claims 1 and 12), comprising: a battery cell(see cell case 200 with cells 110, Figs. 2, 4 & 5, [0055]); and a thermal blocker secured to the battery cell(insulation block 230 is disposed in the open portion 220 of cell case 200, Figs. 2-5, [0081], [0096]-[0097]), the thermal blocker having at least one slot (slot portion 232, Fig. 5, [0091]) that receives a terminal of the battery cell (electrode portion 120, Figs. 2, 4, & 5, [0081]).
Regarding claim 2, Jang discloses further comprising an enclosure assembly (housing 300, Fig. 1, [0055]) that provides an interior area ([0058]) and a cell stack within the interior area(stack of cell cases 200, Figs. 1 & 2, [0125]), the battery cell within the cell stack and disposed along a cell stack axis of the cell stack(Y axis in Figs. 1 & 2).
Regarding claim 4, Jang discloses the thermal blocker is a first thermal blocker secured to a first side of the battery cell (see insulation block 230 on left side of cell case 200 in Figs. 2 & 4) and further comprising a second thermal blocker secured to an opposite second side of the battery cell (see insulation block 230 on right side of cell case 200 in Figs. 2 & 4).
Regarding claim 5, Jang discloses the first and second sides are first and second outboard sides of the battery cell(Figs. 2 & 4).
Regarding claim 6, Jang discloses the battery cell is a pouch-style battery cell(Fig. 4, [0071]).
Regarding claim 7, Jang discloses the terminal is a tab terminal (120, Fig. 4).
Regarding claim 12, Jang discloses a method of managing battery pack thermal energy(abstract, [0020]), comprising: securing a thermal blocker (insulation block 230 is disposed in the open portion 220 of cell case 200, Figs. 2-5, [0081], [0096]-[0097]) to a battery cell to provide a battery cell assembly (see cell case 200 with cells 110, Figs. 2, 4 & 5, [0055]); and after the securing, positioning the battery cell assembly alongside other battery cell assemblies to provide a cell stack(Fig. 1, [0125]).
Regarding claim 14, Jang discloses further comprising receiving a terminal of the battery cell (electrode portion 120, Figs. 2, 4, & 5, [0081]) within an aperture of the thermal blocker(slot portion 232, Fig. 5, [0091]).
Regarding claim 15, Jang discloses the terminal is a tab terminal (120, Fig. 4) and the battery cell is a pouch cell(Fig. 4, [0071]).
Claim Rejections - 35 USC § 103
7. 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.
8. 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.
9. Claim(s) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jang et al. (US 2024/0413479) as applied to claims 1 and 2 above, and further in view of Jang et al. (US 2025/0343299) hereinafter referred to as Jang ‘299.
Regarding claim 3, Jang discloses the battery cell is a first battery cell (200, Fig. 2) and the at least one slot includes a first slot (232, Fig. 5) that receives a terminal of the first battery cell(120, Fig. 5), but does not explicitly disclose the at least one slot of the thermal blocker further including a second slot that receives a terminal of a second battery cell, the second battery cell adjacent to the first battery cell along the cell stack axis.
Jang ‘299 teaches a battery module includes a cell stack including a plurality of battery cells, a module case in which the cell stack is accommodated, and a heat propagation blocking sheet including a heat-resistant material, which covers at least a portion of the cell stack inside the module case(abstract). Jang ‘299 teaches a heat propagation blocking sheet blocks gas, flame, and high-temperature particles ejected from battery cells, a temperature rise and damage to a module case may be prevented([0025]). Jang ‘299 teaches the at least one slot of the thermal blocker (heat propagation blocking sheet 600, Figs. 5-7, [0060]) further including a second slot (slits 622, 632, Fig. 6, [0064]) that receives a terminal of a second battery cell(terminals 113, Fig. 7, [0064]), the second battery cell adjacent to the first battery cell along the cell stack axis(Fig. 7).
It would have been obvious to one of ordinary skill in the art to modify the thermal blocker of Jang with the thermal blocker further including a second slot that receives a terminal of a second battery cell, the second battery cell adjacent to the first battery cell along the cell stack axis as taught by Jang ‘299 in order to prevent a temperature rise and damage to a module case.
10. Claim(s) 8 and 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jang et al. (US 2024/0413479) as applied to claim 1 above, and further in view of Jang et al. (US 2025/0343299) hereinafter referred to as Jang ‘299.
Regarding claim 8, Jang discloses an insulation block coupled to an electrode portion of a cell assembly([0044]) but does not explicitly disclose further comprising an adhesive that secures the thermal blocker to the battery cell.
Jang ‘299 teaches a battery module includes a cell stack including a plurality of battery cells, a module case in which the cell stack is accommodated, and a heat propagation blocking sheet including a heat-resistant material, which covers at least a portion of the cell stack inside the module case(abstract). Jang ‘299 teaches a heat propagation blocking sheet blocks gas, flame, and high-temperature particles ejected from battery cells, a temperature rise and damage to a module case may be prevented([0025]). Jang ‘299 teaches further comprising an adhesive (fireproof tape 640, Fig. 7, [0066]) that secures the thermal blocker (heat propagation blocking sheet 600, Figs. 5-7, [0060]) to the battery cell(110, Fig. 5, [0042]).
It would have been obvious to one of ordinary skill in the art to modify the traction battery assembly of Jang with further comprising an adhesive that secures the thermal blocker to the battery cell as taught by Jang ‘299 in order to prevent a temperature rise and damage to a module case.
Regarding claim 9, modified Jang discloses the adhesive is an adhesive tape (Jang ‘299, fireproof tape 640, Fig. 7, [0066])
11. Claim(s) 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jang et al. (US 2024/0413479) as applied to claim 1 above, and further in view of Bieber et al. (US2024/0368365).
Regarding claim 11, Jang does not explicitly disclose the thermal blocker is foam.
Bieber teaches in an effort to delay or prevent such thermal runaway events and thereby protect nearby structures (e.g., remaining battery cells, vehicle structures, building structures, etc.) and personnel, a thermal insulation/protection barrier has been developed for use within a battery assembly (e.g., in the gap between adjacent battery cells)([0005]). Bieber teaches the barrier includes a cured silicone rubber foam layer comprising a plurality of firming particles disposed within the silicone rubber foam layer in an amount sufficient to impart additional firmness to the silicone rubber foam layer so that it takes a greater compressive force to compress the foam layer to a desired compression value, compared to the same silicone rubber foam layer without the firming particles(abstract).
It would have been obvious to one of ordinary skill in the art to provide the traction battery pack assembly of Jang with the thermal blocker is foam as taught by Bieber, since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as a matter of obvious design choice. MPEP 2144.07.
12. Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jang et al. (US 2024/0413479) as applied to claim 12 above, and further in view of Bieber et al. (US2024/0368365).
Regarding claim 11, Jang does not explicitly disclose the thermal blocker is foam.
Bieber teaches in an effort to delay or prevent such thermal runaway events and thereby protect nearby structures (e.g., remaining battery cells, vehicle structures, building structures, etc.) and personnel, a thermal insulation/protection barrier has been developed for use within a battery assembly (e.g., in the gap between adjacent battery cells)([0005]). Bieber teaches the barrier includes a cured silicone rubber foam layer comprising a plurality of firming particles disposed within the silicone rubber foam layer in an amount sufficient to impart additional firmness to the silicone rubber foam layer so that it takes a greater compressive force to compress the foam layer to a desired compression value, compared to the same silicone rubber foam layer without the firming particles(abstract).
It would have been obvious to one of ordinary skill in the art to provide the traction battery pack assembly of Jang with the thermal blocker is foam as taught by Bieber, since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as a matter of obvious design choice. MPEP 2144.07.
Allowable Subject Matter
13. Claim 10 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 the thermal blocker is adhesively secured directly to an outer case of the battery cell from which the terminal extends, the thermal blocker including a notch that receives a portion of the outer case.
Jang does not disclose, teach or render obvious the thermal blocker is adhesively secured directly to an outer case of the battery cell from which the terminal extends, the thermal blocker including a notch that receives a portion of the outer case.
14. Claim 13 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 further comprising adhesively securing the thermal blocker directly to an outer case of the battery cell, a terminal of the battery cell extending from the outer case through an aperture in the thermal blocker.
Jang does not disclose, teach or render obvious further comprising adhesively securing the thermal blocker directly to an outer case of the battery cell, a terminal of the battery cell extending from the outer case through an aperture in the thermal blocker.
15. The following is a statement of reasons for the indication of allowable subject matter: the invention in independent claim 20 is directed to a traction battery pack assembly, comprising:
a pouch-style battery cell having an outer case and a tab terminal that extends from the outer case; and a foam thermal blocker adhesively secured to the outer case of the battery cell, the foam thermal blocker having a slot through which the tab terminal extends and a notch that receives a portion of the outer case, the battery cell and the foam thermal blocker together providing a battery cell assembly configured to be positioned along a cell stack axis alongside other battery cell assemblies.
Jang discloses a traction battery pack assembly(abstract, claims 1 and 12), comprising:
a pouch-style battery cell (Fig. 4, [0071]) having an outer case (200, Fig. 3, [0081]) and a tab terminal that extends from the outer case(120, Fig. 4, [0081]); but does not disclose, teach or render obvious a foam thermal blocker adhesively secured to the outer case of the battery cell, the foam thermal blocker having a slot through which the tab terminal extends and a notch that receives a portion of the outer case, the battery cell and the foam thermal blocker together providing a battery cell assembly configured to be positioned along a cell stack axis alongside other battery cell assemblies.
Response to Arguments
16. Applicant's arguments filed 6/29/26 have been fully considered but they are not persuasive.
Applicant’s argument: Jang's treatment of the insulation block confirms that it is not, and is not intended to be, secured to the battery cell. Jang configures the block so that its location is "maintained at the open portion 220 but not constantly fixed" ([0099]), held only "by a proper fixing strength designed through a functional relation with the internal pressure caused by venting gas" ([0099]). Under that internal pressure, the block is designed to break free and "move outward from the open portion 220" ([0098], [0107]), so that one end "naturally enters the entry hole 371" of the venting frame on the pack housing ([0108]-[0109]). The retention methods Jang describes are correspondingly sacrificial - for example, taping "that is broken or becomes weaker when a threshold is exceeded" and "adhesive coating having lower adhesive strength than an external force that is larger than a designed reference value" ([0100]). A block that must remain free to release from the cover and translate toward a separate venting frame could not perform Jang's intended function if it were instead secured to the battery cell. Jang thus not only fails to disclose a thermal blocker secured to the battery cell, but affirmatively teaches a block that is held releasably at the cover and migrates away from the cell during a thermal event.
Because Jang does not disclose a thermal blocker secured to the battery cell as recited, Jang does not anticipate claim 1.
Examiner’s Answer: Jang discloses FIG. 5 is a diagram illustrating an insulation block according to an embodiment of the present disclosure, coupled to an electrode portion of a cell assembly. Claim 1 does not recite what secures the thermal blocker to the battery cell.
Applicant’s argument: Independent claim 12 recites "securing a thermal blocker to a battery cell to provide a battery cell assembly; and after the securing, positioning the battery cell assembly alongside other battery cell assemblies to provide a cell stack." For the reasons given above with respect to claim 1, Jang does not disclose securing a thermal blocker to a battery cell.
Examiner’s Answer: Jang discloses FIG. 5 is a diagram illustrating an insulation block according to an embodiment of the present disclosure, coupled to an electrode portion of a cell assembly. Claim 12 does not recite what secures the thermal blocker to the battery cell.
17. Applicant’s arguments, see pages 6-7, filed 6/29/26, with respect to claim 10 have been fully considered and are persuasive. The rejection of claim 10 has been withdrawn.
18. Applicant’s arguments with respect to claim(s) 3, 8, 9, 11, and 16 have been considered but are moot because the new ground of rejection does not rely on the combination of references applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
19. Applicant’s arguments, see pages 9-10, filed 6/29/26, with respect to claim 13 have been fully considered and are persuasive. The rejection of claim 13 has been withdrawn.
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.
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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.
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/VICTORIA H LYNCH/Primary Examiner, Art Unit 1724
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