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
Claim 13-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 08/10/2026.
Specification
The disclosure is objected to because of the following informalities:
[0032] includes a period between “normal battery operations” and “a pressure relief device” where a comma is expected.
[0034] is missing terminal punctuation.
[0041] recites “for housing assembly the battery arrays”, it is assumed this contains an erroneous “assembly”.
[0048] recites “a basing member”, it is assumed this should be “a biasing member”.
[0050] recites “can continued to move”, it is assumed this should be “can continue to move”.
[0053] recites “ratchet mechanism could the second plurality of teeth”, it is assumed there is an omitted verb after “could”.
Appropriate correction is required.
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 9 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.
Regarding claim 9, the claim recites “the valve member translates along an axis when moving from the closed position to the locked-release position” it is unclear which locked-release position this refers to, either the original “locked-release position” of claim 1 or one of the two “locked-release positions” introduced in claim 8.
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.
(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.
Claim(s) 1-2, 4, 6-7, and 12 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Raettich (US 20230198086 A1).
Regarding claim 1, Raettich discloses “a traction battery assembly (Raettich, [0007]), comprising: an enclosure assembly (Raettich, [0023], battery housing 1) having an interior area (Raettich, [0023], interior space 3); a pressure relief device (Raettich, [0023], valve apparatus 4) having a valve member (Raettich, [0023], valve body 6) movable from a closed position (Raettich, [0023], …valve body 6…shown in a closed position…) to an unlocked-release position (Raettich, [0024], …valve body 6 can be moved between the closed position and a first open position…), and movable from the unlocked-release position to a locked-release position (Raettich, [0025], …valve body 6 is moved beyond the first open position into a second open position and fixed…), the valve member in the closed position blocking flow through the pressure relief device from the interior area (Raettich, [0023], …seals the degassing opening…), the valve member in the unlocked-release position permitting flow from the interior area (Raettich, [0024], …to equalize the pressure between the interior space 3 and the surrounding area 12), the valve member in the locked-release position permitting flow from the interior area (Raettich, [0025], …the hot gas can escape from the interior space 3 into the surrounding area 12); and a ratchet mechanism that holds the valve member in the locked-release position (Raettich, [0025], snap hook 15, snap hook head 17, and undercut 16)”.
Regarding claim 2, Raettich discloses “the valve member is free to move back-and-forth between the closed position and the unlocked-release position (Raettich, [0024], …valve body 6 can be moved between the closed position and a first open position)”.
Regarding claim 4, Raettich discloses “a biasing device (Raettich, [0024], resetting device 9) that biases the pressure relief device to the closed position (Raettich, [0024], …resetting device 9 draws valve body 6 back to the housing wall 2…)”.
Regarding claim 6, Raettich discloses “the ratchet mechanism includes at least one tooth (Raettich, [0025], snap head hook 17)”.
Regarding claim 7, Raettich discloses “the ratchet mechanism is configured to block movement of the valve member from the locked-release position back to the unlocked-release position when the ratchet mechanism holds the valve member in the locked-release position (Raettich, [0025], …fix the valve body 6 in the second open position)”.
Regarding claim 12, Raettich discloses “the valve member is configured to move from the closed position to the unlocked-release position in response to a pressure within the interior area exceeding a pressure outside the interior area by a first amount (Raettich, [0024], …first threshold value), wherein the valve member is configured to move from the unlocked-release position to the locked-release position in response to the pressure within the interior are exceeding the pressure outside the interior area by a second amount that is greater than the first amount (Raettich, [0024], …second threshold value)”.
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.
Claim(s) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Raettich (US 20230198086 A1).
Regarding claim 3, Raettich does not disclose “the valve member in the locked-release position permits more flow from the interior area than the valve member in the unlocked-release position”. However, Raettich does disclose that to reach the second open position the internal pressure must exceed a second threshold value which is greater than a first threshold value needed to reach the first open position (Raettich, [0013]). The examiner notes that this would cause a greater pressure differential in the case of when the valve member is in the second open position than if it were in the first open position leader to greater flow in the second open position than in the first.
Therefore, it would have been obvious to one skilled in the art before the effective filling date of the invention that the design of Raettich allows for greater flow in the second open position than in the first open position.
Claim(s) 5, and 8-10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Raettich (US 20230198086 A1) in view of Lu et al. (CN 114033872 A, hereinafter Lu).
Regarding claim 5, Raettich does not disclose “the biasing device is a coil spring”. Raettich only discloses its resetting device as a general spring (Raettich, [0024], spring 10). However, Lu teaches a pressure relief valve in a power battery (Lu, [0001]) with a spring used to bias the valve to the closed position (Lu, Fig.1, limit spring 400).
Therefore, it would have been obvious to one skilled in the art before the effective filling date of the invention to substitute the spring of Raettich with the coiled spring of Lu because the substituted component was known, their function were known in the art, one of ordinary skill in the art could have substituted one known component for another and that the result of the substitution would have been predictable. See MPEP 2143 (B).
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Regarding claim 8, Raettich does not disclose “the ratchet mechanism is configured to hold the valve member in a first locked-release position that permits a first amount of flow from the interior area, wherein the ratchet mechanism is further configured to hold the valve member in a second locked-release position that permits a second amount of flow from the interior area, the second amount of flow greater than the first amount of flow”. Raettich only discloses a single locked-release position (Raettich, [0025], …valve body 6 is moved beyond the first open position into a second open position and fixed). However, Lu teaches a pressure relief valve in a power battery (Lu, [0001]) with said relief valve having ratchet mechanism with a first locked open position (Lu, [0070) and a second locked open position (Lu, [0072) where exhaust volume is increased (Lu, [0072]). Lu additionally teaches that step-by-step approach helps reduce pressure load on the battery during extreme thermal runaway events (Lu, [0072]).
Therefore, it would have been obvious to one skilled in the art before the effective filling date of the invention to substitute the ratchet and valve mechanism of Raettich with the rachet and valve mechanism of Lu to help better protect sensitive battery internals form overpressure because the substituted component was known, their function were known in the art, one of ordinary skill in the art could have substituted one known component for another and that the result of the substitution would have been predictable. See MPEP 2143 (B).
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Regarding claim 9, Lu teaches “the valve member translates along an axis when moving from the closed position to the locked-release position (Lu, [0073], …check member 110 can move along the axial direction of the valve stem 100 in a direction away from the valve body 300…), the ratchet mechanism having a first plurality of teeth circumferentially distributed about the axis that hold the valve member in the first locked-release position, the ratchet mechanism having a second plurality of teeth circumferentially distributed along the axis that hold the valve member in the second locked-release position (Lu, [0063], …may be multiple elastic check member 110, each elastic check member 110 having multiple compression portions 111, see Fig.7 above for instance where there is a single tooth for each position)”.
Regarding claim 10, Lu teaches “a plurality of fingers of the pressure relief device, the plurality of fingers circumferentially distributed about the valve member, each of the fingers within the plurality of fingers including at least one of the teeth in the first plurality of teeth, and at least one of the teeth in the second plurality of teeth (Lu, [0063], …may be multiple elastic check member 110, each elastic check member 110 having multiple compression portions 111)”.
Claim(s) 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Raettich (US 20230198086 A1) in view of Brown et al. (WO 2023278340 A1, hereinafter Brown).
Regarding claim 11, Raettich does not disclose “a plurality of battery arrays housed inside the enclosure assembly”. However, Brown teaches a battery module comprising multiple electrically connected cell-brick assemblies with each comprising a collection of cells (Brown, [0003]). Brown further teaches these cells housed within a housing (Brown, [0032]-[0034]).
Therefore, it would have been obvious to one skilled in the art before the effective filling date of the invention to house the multiple cell-brick assemblies of Brown in the housing and interior space of Raettich because it would impart the known benefit of allowing a greater capacity for the battery system.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOSHUA P BISTANY-RIEBMAN whose telephone number is (571)272-9591. The examiner can normally be reached Mon-Fri. 7:30am-5pm.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Nicholas A Smith can be reached at 5712728760. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/JOSHUA P BISTANY-RIEBMAN/Examiner, Art Unit 1752
/NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
