DETAILED ACTION
Introductory Notes
Any paragraph citation of the instant is in reference to the U.S. published patent application.
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 Species A, Figure 1 in the reply filed on 6/9/2026 is acknowledged.
Notably Figure 1 shows all components of claim 1 as well as the following:
Claim 2’s expansion
Claim 3’s cylinder or bag
Claim 4’s temperature sensor
Claim 5’s maintenance valve
Claim 6’s pressure reducing valve
Claim 12’s battery module and housing
Conversely the aspects of claims 7-11 are shown in Figures 2 and 3 and belong to Species B and C as follows:
Claims 7-10 incorporate a solenoid valve, auxiliary accumulator, pressure sensor, and a maintenance valve. All drawn to Species B and shown in Fig. 2.
Claim 11 incorporates a pump and is drawn to Species C as shown in Fig. 3.
Claims 7-11, as selected by Examiner due to no designation of claims in the response, are therefore withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected Species, there being no allowable generic or linking claim. Election of the Species was made without traverse in the reply filed on 6/9/2026.
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.
Claims 1-3 are rejected under 35 U.S.C. 103 as being unpatentable over LEE (US 20220077550 A1, supplied with an IDS)
Regarding claim 1, LEE discloses a pressure maintenance device (“a secondary battery module capable of maintaining a constant surface pressure of a battery cell” [0002]) comprising:
a hydraulic device (“pressure pad 300” [0011]) inside a housing (battery case 200) of a battery module (secondary battery module 1000) together with a plurality of battery cells (battery stack 100 with battery cells 100A), the hydraulic device being configured to change its volume to offset a pressure change inside the housing due to deformation of the plurality of battery cells (“adjusting the volume of the pressure pad 300 in response to the expansion and contraction of the battery cells 100A” [0032]);
an accumulator (pressure adjusting unit 400 as well the volume within the passages shown as dashed lines in Figs. 1-3) connected to the hydraulic device through a pipe (fluid inlet 330 and fluid outlet 340), the accumulator being configured to store fluid and to discharge the fluid to the pipe or to store the fluid introduced from the pipe according to a change in a volume of the hydraulic device (“pressure adjusting unit 400 that adjusts the volume of the pressure pad 300 in response to a measured pressure” [0031]);
a heater configured to heat the accumulator (“temperature adjusting unit 600 that adjusts a temperature of fluid moving to the pressure pad 300” [0038]);
and a controller (temperature measuring unit 700 working in conjunction with temperature adjusting unit 600, see [0038-0039]).
LEE does not expressly teach a relationship between the heater and outdoor air temperature.
However, LEE discloses “the temperature measuring unit 700 measures the temperature of the battery cells 100A … provides real-time temperature information … to control the cooling device or the heater of the battery module as well as to adjust the temperature of the fluid flowing into the pressure pad 300, thereby making it possible to more constantly maintain the temperature of the battery cells 100A”. As such LEE teaches maintenance of battery temperature. One of ordinary skill in the art would recognize ambient temperature is a contributing factor of battery module temperature, therefore LEE’s maintenance of battery temperature demonstrates control of the heater based at least in part on the ambient temperature. Examiner recognizes the instant utilizes temperature sensor 27 for the purpose of preventing “pressure change inside the accumulator 22 from occurring due to a temperature change inside the accumulator 22” [0047]. However, this purpose is not fully encompassed by the limitation of Claim 1 and under a broadest reasonable interpretation the structure of LEE controls the heater according to outside air temperature without modification.
Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art that outdoor air temperature contributes to battery module temperate. Therefore, LEE discloses a controller configured to control the heater according to an outdoor air temperature.
Regarding claim 2, LEE discloses when the plurality of battery cells expand, the hydraulic device is configured to contract to discharge the fluid to the pipe, and when the plurality of battery cells contract, the hydraulic device is configured to expand by the fluid introduced from the pipe (“during a charging/discharging process, the battery cells 100A are contracted or expanded” [0032] as well as “appropriately adjusting the volume of the pressure pad 300 in response to the expansion and contraction of the battery cells 100A” [0032]).
Regarding claim 3, LEE discloses the hydraulic device comprises a hydraulic cylinder or a hydraulic bag (pressure pad 300 has accommodating space 301 and is a “a soft material, such as natural rubber or synthetic resin, so that the volume may be changed” [0037] reading on hydraulic bag).
Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over LEE in view of CHOPARD (US 20220123389 A1).
Regarding claim 4, LEE discloses “the pressure pad 300 that is disposed in close contact with the battery cells 100A to exchange heat with the battery cells 100A” [0039] as well as a “battery cell temperature control unit to control the cooling device or the heater of the battery module” [0039], however LEE does not expressly teach an outdoor air temperature sensor.
CHOPARD is directed to supplying fluid to a battery module and cooling the module, like LEE. CHOPARD discloses “a first temperature sensor for sensing the temperature on or near said cells or groups of cells, and a second temperature sensor for sensing the temperature of the environment outside the vehicle” [0060]. CHOPARD teaches “taking into account: temperature data (Tcell) at least from the first temperature sensor 45 … temperature data (Tamb) at least from the second temperature sensor 79” [0220] as well as “it will be possible to favour a predictive (anticipatory) management of the battery temperature” [0223]. Regarding benefits of the sensor(s) CHOPARD teaches “the thermal management of the battery may be finely controlled, in a gradual manner, and the unnecessary use of fluid may be avoided” [0069].
Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art to utilize the external temperature sensor of CHOPARD in the battery module system of LEE. The motivation to do so being efficient and finely controlled management of the thermal state of the battery module.
Therefore, modified LEE discloses a temperature sensor configured to detect the outdoor air temperature (as taught by CHOPARD).
Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over LEE in view of PELGER (US 20170016579 A1).
Regarding claim 5, LEE discloses a fluid system as shown in Figs. 1-3 and is concerned with the pressure adjusting unit of a battery module, specifically for a vehicle (see claim 15). However, LEE does not expressly teach fluid handling details such as a maintenance valve.
PELGER is directed to system for storing a pressurized gas in a motor vehicle, like LEE. PELGER discloses Fig. 1 wherein tank valve 14 includes a service valve, noted in the figure below, which allows the storage vessel 12 to be charged.
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PELGER teaches a “pressurized-gas storage vessel of said type duly normally has so-called service valves” [0005], thus further establishing a service (or maintenance or charging) valve as known to one of ordinary skill in the art.
Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art to include the service valve of PELGER as a means of pressurizing the pressure adjusting unit of LEE. The motivation to do so being to pressurize the system via an external source.
Therefore, modified LEE discloses a maintenance valve connected to the pipe (connected via the pressure adjusting unit of LEE), and wherein the maintenance valve is configured to be opened to supplement the fluid to the pipe (as taught by PELGER).
Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over LEE in view of PHLEGM (US 20230299365 A1).
Regarding claim 6, LEE discloses a fluid system as shown in Figs. 1-3. However, LEE does not expressly teach fluid handling details such as a pressure reducing valve.
PHLEGM is directed to an apparatus for constant pressure regulation of one or more battery cells, like LEE. PHLEGM discloses pressure relief valve 62. PHLEGM teaches “pressure relief valve disposed in fluid communication with the passageway for releasing gas from the chamber when the gas pressure is greater than a maximum allowable pressure” [0004].
Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art to utilize the pressure relief valve of PHLEGM in the pressurized system of LEE. The motivation to do so being to provide a means to release gas when the pressure is greater than the maximum allowed.
Therefore, modified LEE discloses a pressure reducing valve connected to the pipe, and wherein the pressure reducing valve is configured to be opened when a pressure inside the pipe exceeds a reference value to discharge the fluid from the pipe (as taught by PHLEGM ).
Claim 12 is rejected under 35 U.S.C. 103 as being unpatentable over LEE in view of LONG (US 20250007037 A1).
Regarding claim 12, LEE discloses a battery system comprising: the pressure maintenance device according to claim 1 (as discussed in the rejection of claim 1); and the battery module, the battery module comprising: the plurality of battery cells stacked adjacent to each other (as shown in Figs. 1-3).
LEE discloses a fluid system as shown in Figs. 1-3 and is concerned with the pressure adjusting unit of a battery module, specifically for a vehicle (see claim 15). However, LEE does not expressly teach the battery module housing is airtight.
LONG is directed to a battery module for an electric vehicle, like LEE. LONG discloses a thermal management system incorporating inlet/outlet pipes 422 and 423 which pass through case 10 (see Figs. 2 and 5) via “through holes” [0016]. LONG discloses “a sealing member, such as a sealant and a seal ring, etc., may be arranged between the accommodating frame 12 and the top cover 30 or the bottom cover 11” [0181] which LONG teaches allows the case “to hermetically protect the battery module 20” [0180], thus any through holes, such as those for the inlet and outlet pipes are also sealed.
Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art to utilize the hermetically sealed case of LONG (reading on airtight) for the battery module of LEE. The motivation to do so being to hermetically protect the battery module.
Therefore, modified LEE discloses the housing having an airtight space in which the plurality of battery cells and the hydraulic device are arranged (as taught by LONG).
Conclusion
The prior art made of record and not relied upon considered pertinent to applicant's disclosure:
KIM (US 20220393284 A1) directed to a battery module capable of maintaining constant surface pressure of battery cells.
KAUFMANN (US 20220271326 A1) directed to a flexible tensioning device for exerting a predetermined force on the plurality of battery cells in the discharged state and in the charged state.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to TRAVIS L MARTIN whose telephone number is (703)756-5449. The examiner can normally be reached M-F, 8am-5pm ET.
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, Allison Bourke can be reached at (303)297-4684. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/T.L.M./Examiner, Art Unit 1721
/ALLISON BOURKE/Supervisory Patent Examiner, Art Unit 1721
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