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 .
The Applicant’s amendment filed on 8/6/2026 was received. Claims 1, 11, 12 were amended. Claims 17-20 were newly added.
The text of those sections of Title 35, U.S.C. code not included in this action can be found in the prior Office action issued on 5/14/2026.
Claim Rejections - 35 USC § 112
The claim rejections 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(or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention on claims 1, 11, 12 are withdrawn because Applicant amended claims 1, 11, 12.
Claim Rejections - 35 USC § 103
The claim rejections under 35 U.S.C. 103 as being unpatentable over Jo (US 20220200102 A1) in view of Watahiki et al. (US 20200321589 A1) on claims 1-16 are withdrawn because Applicant amended independent claim 1.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Jo (US 20220200102 A1) in view of Yamamoto et al. (US 20200035979 A1).
Regarding claim 1: Jo discloses a bus bar for battery module transportation and an insulating case (par. 2). The battery module (10) comprising:
a fusing bus bar (110) (equivalent to a second path of a terminal member) (par. 31, fig. 2) electrically connected to one end of a battery module (10) (par. 30), the fusing bus bar (110) including a bent part (113) (equivalent to a fuse portion) (par. 44, fig. 5); and
a grid structure (equivalent to an arc interruption portion) (par. 36, fig. 1-3) located in a discharging space (the space above the fusing bus bar (110) is equivalent to a discharging space) in which sparks (equivalent to an arc) escaped when the battery module (10) has a short circuit (par. 40) (equivalent to a time of melting and disconnection of the fuse portion), the grid structure being provided to extend in a direction orthogonal to a direction in which the bent part (113) and the discharging space are arranged side by side (see fig. below),
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Jo fails to explicitly disclose a plurality of battery cells arranged side by side in one direction, each of the plurality of battery cells having a prismatic shape. However, Yamamoto et al. disclose an energy storage apparatus (abstract). The energy storage apparatus (1) (equivalent to a battery module) comprises a plurality of energy storage devices (100) (equivalent to battery cells) arranged side by side in one direction (par. 73, fig. 3), each of the plurality of battery cells having a prismatic shape (fig. 3). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to include the plurality of energy storage devices (100) of Yamamoto et al. in the battery module of Jo because Yamamoto et al. teach that the energy storage devices (100) arranged in this way can be used for power storage application, power source application or the like (par. 72). In addition, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to arrange the battery cells of Jo in the manner taught by Yamamoto et al. as this is a known and suitable arrangement for the battery cells in the battery module in the art. Further, it is a matter of engineering design to arrange the battery cells in different ways, where the change in form or shape, without any new or unexpected result, is an obvious engineering design. See In re Dailey, 149 USPQ 47 (CCPA 1966) (see MPEP § 2144.04). Finally, one would have a reasonable expectation of success by changing the arrangement of the battery cells to the claimed limitation as Yamamoto et al. teach this arrangement is a known and suitable arrangement in the art.
Jo fails to explicitly disclose the terminal member includes a first path, a third path, and a fourth path, the first path is located above the at least one battery cell in a height direction of the battery module, and has a joining portion at which the terminal member is electrically connected to an electrode terminal of the at least one battery cell, the second path is connected to the first path, extends in a direction in which a positive electrode terminal and a negative electrode terminal of the at least one battery cell are arranged side by side, and includes the fuse portion, the third path is connected to the second path and extends in the one direction in which the plurality of battery cells are arranged side by side, and the fourth path is connected to the third path and extends in a plane, the plane being constituted by the direction in which the positive electrode terminal and the negative electrode terminal of the at least one battery cell are arranged side by side, and the height direction of the battery module. However, Yamamoto et al. further disclose the energy storage apparatus (1) comprising:
a bus bar (131) (equivalent to a first path) (par. 92, fig. 4) is located above the at least one energy storage device (100) in a height direction of the energy storage apparatus (1) (fig. 3), and has a through hole (131b) (equivalent to a joining portion) (par. 115, fig. 3, 4) at which the bus bar (131) is electrically connected to an negative electrode terminal (130) of the energy storage device (104) (par. 115),
a circuit breaking part (40) (equivalent to a second path) is connected to the bus bar (131), extends in a direction in which a positive electrode terminal and a negative electrode terminal of the at least one the energy storage device (100) are arranged side by side, and includes a fuse (par. 74, 108, fig. 3, 4),
a first portion of the bus bar (132) (equivalent to a third path) (see fig. below) is connected to the circuit breaking part (40) and extends in the one direction in which the plurality of energy storage devices (100) are arranged side by side (par. 117, fig. 3, 4), and
a second portion of the bus bar (132) (equivalent to the fourth path) (see fig. below) is connected to the first portion of the bus bar (132) and extends in a plane, the plane being constituted by the direction in which the positive electrode terminal and the negative electrode terminal of the at least one energy storage device (100) are arranged side by side, and the height direction of the energy storage apparatus (1) (fig. 4).
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It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to include the bus bar (131) and the bus bar (132) of Yamamoto et al. into the battery module (10) of Jo and use the bus bar (131) and the bus bar (132) of Yamamoto et al. to connect the fusing bus bar (110) of Jo because Yamamoto et al. teaches that the bus bars have the insulation structure and the simple structure (par. 7).
Regarding claim 2: Jo discloses an upper housing (130) (par. 30, fig. 1, 2) (equivalent to a cover member) that covers the bent part (113) (fig. 3), wherein
the upper housing (130) is provided with an opening that faces the discharging space (par. 36, 40, fig. 3, 4).
Regarding claim 3: Jo discloses a wall surface portion located between the bent part (113) and the grid structure, wherein
the wall surface portion at least partially surrounds the discharging space when viewed in the direction in which the bent part (113) and the discharging space are arranged side by side (see fig. below).
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Regarding claims 4, 5: Jo discloses the upper housing (130) includes a beam portion (see fig. below) provided to extend across the opening, the beam portion constituting the grid structure (par. 36, fig. 1-3).
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Regarding claims 6, 7, 8: Jo discloses an insulating case (100) (par. 30, fig. 1) (equivalent to a holder) that supports the fusing bus bar (110) (par. 33, fig. 2), wherein the insulating case (100) includes an upper housing (130) (par. 30), and the upper housing (130) includes a beam portion that constitutes the grid structure (par. 36, see fig. above).
Regarding claims 9, 10: Jo discloses the beam portion extends in a direction in which an electric conduction path including the bent part (113) in the fusing bus bar (110) extends (see fig. below).
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Regarding claims 11, 12: Jo discloses the beam portion extends in a thickness direction of the beam portion (a thickness direction is out of the plane of sheet in fig. 3). The thickness direction of the beam portion is orthogonal to a direction in which an electric conduction path including the bent part (113) in the fusing bus bar (110) extends.
Regarding claims 13, 14: Jo in view of Yamamoto et al. discloses a bus bar for battery module transportation and an insulating case as described above. Jo fails to explicitly disclose the discharging space is formed on a side opposite to the plurality of battery cells with respect to the terminal member. However, Yamamoto et al. disclose an energy storage apparatus (abstract). The energy storage apparatus (1) (equivalent to a battery module) includes a plurality of energy storage devices (100) (equivalent to battery cells) (par. 73, fig. 3), bus bars (131, 132) (par. 92, 117, fig. 4), and a circuit breaking part (40) (par. 74, fig. 3, 4) (a combination of the bus bars (131, 132) and the circuit breaking part (40) is equivalent to a terminal member) (the space above the circuit breaking part (40) is equivalent to the discharging space). The energy storage device (100) is placed below the bus bars (131, 132) and the circuit breaking part (40) (fig. 3, 4). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to use the opposite side of the bus bars (131, 132) and the circuit breaking part (40) (equivalent to the terminal member) of Yamamoto et al. for placing the plurality of battery cells of Jo because Yamamoto et al. teach this design can make the bus bars have the insulation structure and the simple structure (par. 7).
Regarding claims 15, 16: Jo discloses the grid structure is disposed at a position displaced with respect to a center of the bent part (113) when viewed in the direction in which the bent part (113) and the discharging space are arranged side by side (see fig. below).
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Regarding claim 17: Jo in view of Yamamoto et al. discloses a bus bar for battery module transportation and an insulating case (par. 2) as described above. Jo fails to explicitly disclose the first path extends while being bent in the direction in which the positive electrode terminal and the negative electrode terminal of the at least one battery cell are arranged side by side, the one direction in which the plurality of battery cells are arranged side by side, and the height direction of the battery module. However, Yamamoto et al. disclose an energy storage apparatus (abstract). The energy storage apparatus (1) (equivalent to a battery module) comprises the bus bar (131) (equivalent to the first path) (par. 92, fig. 4). The bus bar (131) extends while being bent in the direction in which the positive electrode terminal and the negative electrode terminal of the at least one energy storage device (100) (equivalent to battery cell) are arranged side by side (x direction in fig. 4), the one direction in which the plurality of energy storage devices (100) are arranged side by side ( y direction in fig. 4), and the height direction of the energy storage device (100) (z direction in fig. 4). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to include the bus bar (131) of Yamamoto et al. into the battery module (10) of Jo and use the bus bar (131) of Yamamoto et al. to connect the fusing bus bar (110) of Jo because Yamamoto et al. teaches that the bus bar has the insulation structure and the simple structure (par. 7).
Regarding claim 18: Jo discloses the bent part (113) (equivalent to the fuse portion) has a width narrower than a width of a portion of the fusing bus bar (110) other than the bent part (113) (par. 44, 48, fig. 5).
Regarding claim 19: Jo in view of Yamamoto et al. discloses a bus bar for battery module transportation and an insulating case (par. 2) as described above. Jo and Yamamoto et al. fail to explicitly disclose a width of the third path is equal to a width of the first path. However, while the Yamamoto reference does not explicitly disclose the specific width of the bus bars (131, 132), it would have been obvious to one of ordinary skill in the art at the time of the invention to make the width of the bus bars (131, 132) the same and also wider than the width of the circuit breaking part (40) (Yamamoto teaches a narrower width of the circuit breaking par in par. 75), so that the circuit is broken at the desired location (the circuit breaking part (40)) when a short-circuiting happens. Such a modification would have involved a mere change in the size (or dimension) of a component. A change in size (dimension) is generally recognized as being within the level of ordinary skill in the art. In re Rose, 220 F.2d 459, 105 USPQ 237 (CCPA 1955). Where the only difference between the prior art and the claims is a recitation of relative dimensions of the claimed device, and the device having the claimed dimensions would not perform differently than the prior art device, the claimed device is not patentably distinct from the prior art device, Gardner v. TEC Systems, Inc., 725 F.2d 1338, 220 USPQ 777 (Fed. Cir. 1984), cert. denied, 469 U.S. 830, 225 USPQ 232 (1984).
Regarding claim 20: Jo in view of Yamamoto et al. discloses a bus bar for battery module transportation and an insulating case (par. 2) as described above. Jo fails to explicitly disclose the fourth path is electrically connected to an external terminal. However, Yamamoto et al. disclose an energy storage apparatus (abstract). The energy storage apparatus (1) (equivalent to a battery module) comprises the second portion of the bus bar (132) (equivalent to the fourth path) (par. 117, see fig. above). The second portion of the bus bar (132) is electrically connected to a negative electrode external terminal (30) (par. 106, fig. 4). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to include the bus bar (132) of Yamamoto et al. into the battery module (10) of Jo and use the bus bar (132) of Yamamoto et al. to connect the fusing bus bar (110) of Jo because Yamamoto et al. teaches that the bus bar has the insulation structure and the simple structure (par. 7).
Response to Amendment
Applicant’s arguments filed on 08/06/2026 have been fully considered but they are not persuasive. Applicant primarily argues:
Jo and Watahiki do not teach or suggest the terminal member includes a first path, a second path, a third path, and a fourth path.
In response:
Applicant’s arguments are not moot. Newly cited reference, Yamamoto, teaches a first path, a second path, a third path, and a fourth path as described in paragraph 4 above.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to PIN JAN WANG whose telephone number is (571)272-7057. The examiner can normally be reached M-F 9am-5pm.
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/PIN JAN WANG/Examiner, Art Unit 1717
/Dah-Wei D. Yuan/Supervisory Patent Examiner, Art Unit 1717