Prosecution Insights
Last updated: October 01, 2026
Application No. 18/490,412

SCALABLE MANUFACTURING PROCESS FOR BATTERY CELLS WITH STACKED ELECTRODES

Non-Final OA §103§112
Filed
Oct 19, 2023
Examiner
WEST, ROBERT GENE
Art Unit
4100
Tech Center
4100
Assignee
GM Global Technology Operations LLC
OA Round
2 (Non-Final)
75%
Grant Probability
Favorable
2-3
OA Rounds
4m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allowance Rate
89 granted / 119 resolved
+14.8% vs TC avg
Strong +24% interview lift
Without
With
+24.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
53 currently pending
Career history
170
Total Applications
across all art units

Statute-Specific Performance

§103
57.7%
+17.7% vs TC avg
§102
18.6%
-21.4% vs TC avg
§112
22.6%
-17.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 119 resolved cases

Office Action

§103 §112
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 . If status of the application as subject to 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 a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. Status of Claims Claims 1, 3-7, 9-11, 13-15, & 17-20 are pending in the application and are presently examined. Claims 1-20 were rejected in the 5/27/2026 office action. Applicant cancelled claims 2, 8, 12, & 16. Response to Amendment / Arguments The 7/6/2026 amendment, in response to the 5/27/2026 office action, has been entered. Applicant’s claim amendments overcame the 35 U.S.C. 102 rejections; nevertheless, the claims remain rejected under 35 U.S.C. 103. Independent claims 1, 11, & 18 were amended to require an electrically insulating material at outer perimeter of each cathode (previous claim 2) and a spring element between the battery monocells (previous claim 8). As discussed in the 5/27/2026 office action, US20210194041A1 (Park) teaches the spring and US20210384550A1 (Kumagae) teaches the insulating material. Applicant argues: “a spring member positioned between two adjacent cells (as taught by Park in Par. 0020) may only be effective for its intended purpose immersed in a liquid electrolyte, but not effective being embedded in a solid electrolyte” Examiner is not persuaded for the following reasons: First, Examiner couldn’t find any teaching in Park, including in paragraph 20 referred to by Applicant, that the spring is only effective if immersed in a liquid electrolyte. Park illustrates the spring layers 105 between adjacent battery cells 102 (figures 1-2) - not immersed in liquid electrolyte. Second, the present specification states that liquid or solid-state electrolyte may be used (paragraph 16). Third, the present claims don’t require an electrically liquid insulating material. Fourth, the combined prior art would still result in the spring fulfilling its function according to the teachings of the present specification. The present specification teaches that the spring accommodates battery cell expansion (paragraph 42). Applying Park and Kumagae to the primary reference, US20070218355A1 (Ryu), places the spring between Ryu’s batteries with Kumagae’s insulating layer at an outer perimeter. Within the outer perimeter insulating layer, Ryu’s batteries can expand and contract, with this expansion and contraction accommodated by Park’s spring. Applicant next argues: “Furthermore, as Applicant may be his own lexicographer, Applicant's Par. 0046 of the specification as filed unequivocally defines that stacking cathodes 16 in a column is equivalent to ‘tightly arranging’ those cathodes in the subject column.” Examiner disagrees with that “arranging” is unequivocally defined as “tightly arranging”. Paragraph 46 of the present specification states: “Generating the first and second battery monocells 19-1, 19-2 in respective frames 104 and 106 may include tightly arranging or stacking each of the cathodes 16 in a column 62” This statement does not require that “arranging” must mean “tightly arranging”. This is not a clear enough statement to change the meaning of “arranging” to “tightly arranging” (See MPEP 2111.01.IV). If Applicant wants “arranging” in the claims to be “tightly arranging”, then Applicant must amend the claims by replacing “arranging” with “tightly arranging”. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(d): (d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. Claims 4-5 are rejected under 35 U.S.C. 112(d), as being of improper dependent form for failing to further limit the subject matter of the claim upon which they depend. Claims 4-5 merely repeat claim 1 limitations. Applicant may cancel the claims, amend the claims to place the claims in proper dependent form, or present a sufficient showing that the dependent claims comply with the statutory requirements. Claim Rejections - 35 USC § 103 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: Determining the scope and contents of the prior art. Ascertaining the differences between the prior art and the claims at issue. Resolving the level of ordinary skill in the pertinent art. 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. The claims are in bold font, the prior art is in parentheses. Claims 1, 4-7, 10-11, & 14-15 are rejected under 35 U.S.C. 103 as being unpatentable over US20070218355A1 (Ryu) in view of US20160043363A1 (Tajima), US20210384550A1 (Kumagae), and US20210194041A1 (Park). With regard to claim 1, Ryu teaches the following claim 1 limitations: A method of manufacturing a battery cell comprising: providing a battery cell container (paragraph 38: battery case); generating a first battery monocell having a respective anode, cathode, first separator arranged therebetween, and a second separator arranged adjacent to the corresponding anode (paragraph 22; Figure A below); wherein each cathode of the respective first and second battery monocells is defined by a corresponding outer perimeter (Figure A below); wherein generating the first and second battery monocells includes… arranging each cathode in a column (Figure A below)… generating a second battery monocell having a respective anode, cathode, first separator arranged therebetween, and a second separator arranged adjacent to the corresponding anode (paragraph 22; Figure A below); stacking the first battery monocell and the second battery monocell such that the second separator of the first battery monocell is adjacent to the cathode of the second battery monocell (paragraph 22; Figure A below); and arranging the stacked first and second battery monocells in the battery cell container (paragraph 38: mounting the electrochemical cell in a battery case) Figure A: Annotated Ryu Figure 5 PNG media_image1.png 378 1191 media_image1.png Greyscale Ryu, however, fails to teach the following limitations of claim 1, which are taught by Tajima: wherein generating the first and second battery monocells includes: extracting the respective anodes and cathodes from corresponding electrode material sheets via one of die and laser cutting the respective anodes and cathodes from corresponding electrode material sheets Tajima describes laser cutting the active material layer and current collector, because laser cutting can be performed with a high yield (paragraph 103). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have cut out Ryu’s anodes and cathodes with a laser, as taught by Tajima, for high yield. Ryu, however, fails to teach the following limitations of claim 1, which are taught by Kumagae: coating the outer perimeter of each respective cathode (paragraph 76; figures 2B & 6B: positive electrode layer 10A) with an electrically insulating material (paragraphs 63 & 84: insulating material) Kumagae is directed to a solid state battery with reduced cracking & peeling of positive and negative electrode layers during charging and discharging (paragraph 11). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Ryu’s battery to have an electrically insulating material at an outer cathode perimeter, as taught by Kumagae, for a solid state battery with reduced cracking & peeling of positive and negative electrode layers during charging and discharging. Ryu, however, fails to teach the following limitations of claim 1, which is taught by Park: arranging at least one spring element between the first and second battery monocells Park describes a spring, between lithium-ion cells, to control pressure on the cells (paragraphs 1, 4, & 20). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have a spring between Ryu’s batteries, as taught by Park, for pressure control. Claims 4-5 repeat claim 1 limitations, which are discussed above under claim 1. With regard to claim 6, modified Ryu teaches the limitations of claims 1 & 4 as described above. Ryu also teaches the following limitations of claim 6: the electrode material sheets are constructed from respective anode and cathode material, and wherein generating the first and second battery monocells includes coating the respective electrode material onto a corresponding base material foil (paragraph 37) With regard to claim 7, modified Ryu teaches the limitations of claims 1, 4, & 6 as described above. Ryu fails to teach the following limitations of claim 7, which are taught by Tajima (Figure B below): each of the respective anodes and cathodes includes at least one conductive tab, and wherein coating the respective electrode material onto the corresponding base material foil includes generating a respective coated material strip for each of the anodes and the cathodes and at least one exposed material section on each respective base material foil for the corresponding conductive tabs Figure B: Annotated Tajima Figure 2C PNG media_image2.png 371 1063 media_image2.png Greyscale It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have a coated material strip for battery chemical reactions, and exposed material sections, for electrical connection. With regard to claim 10, Ryu teaches the limitations of claim 1 as discussed above. Ryu also teaches the following limitation of claim 10: the battery cell is one of a cylindrical, a prismatic, and a pouch cell (paragraph 38: pouch) Ryu teaches the following claim 11 limitations: A method of manufacturing a lithium-ion (paragraph 23) cylindrical (paragraphs 3-4) battery cell comprising: providing a battery cell container (paragraph 38: battery case); generating a first battery monocell having a respective lithium-metal anode, cathode, first separator arranged therebetween, and a second separator arranged adjacent to the corresponding anode (paragraphs 22; Figure A below) generating a second battery monocell having a respective anode, cathode, first separator arranged therebetween, and a second separator arranged adjacent to the corresponding anode (paragraph 22; Figure A below); wherein each cathode of the respective first and second battery monocells is defined by a corresponding outer perimeter (Figure A below)… arranging each cathode in a column (Figure A below)… stacking the first battery monocell and the second battery monocell such that the second separator of the first battery monocell is adjacent to the cathode of the second battery monocell (paragraph 22; Figure A below); and arranging the stacked first and second battery monocells in the battery cell container (paragraph 38: mounting the electrochemical cell in a battery case) Figure A: Annotated Ryu Figure 5 PNG media_image1.png 378 1191 media_image1.png Greyscale Ryu, however, fails to teach the following limitations of claim 11, which are taught by Tajima: wherein generating the first and second battery monocells includes extracting the respective anodes and cathodes from corresponding electrode material sheets via one of die and laser cutting the respective anodes and cathodes from corresponding electrode material sheets (paragraph 103) Ryu, however, fails to teach the following limitations of claim 1, which are taught by Kumagae: coating the outer perimeter of each respective cathode (paragraph 76; figures 2B & 6B: positive electrode layer 10A) with an electrically insulating material (paragraphs 63 & 84: insulating material) Kumagae is directed to a solid state battery with reduced cracking & peeling of positive and negative electrode layers during charging and discharging (paragraph 11). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Ryu’s battery to have an electrically insulating material at an outer cathode perimeter, as taught by Kumagae, for a solid state battery with reduced cracking & peeling of positive and negative electrode layers during charging and discharging. Ryu, however, fails to teach the following limitations of claim 1, which is taught by Park: arranging at least one spring element between the first and second battery monocells Park describes a spring, between lithium-ion cells, to control pressure on the cells (paragraphs 1, 4, & 20). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have a spring between Ryu’s batteries, as taught by Park, for pressure control. With regard to claim 14, modified Ryu teaches the limitations of claim 11 as described above. Ryu also teaches the following limitations of claim 14: wherein the electrode material sheets are constructed from respective anode and cathode material, and wherein generating the first and second battery monocells includes coating the respective electrode material onto a corresponding base material foil (paragraph 37) With regard to claim 15, modified Ryu teaches the limitations of claims 11 & 14 as described above. Ryu fails to teach the following limitations of claim 15, which are taught by Tajima (Figure B below): wherein each of the respective anodes and cathodes includes at least one conductive tab, and wherein coating the respective electrode material onto the corresponding base material foil includes generating a respective coated material strip for each of the anodes and the cathodes and at least one exposed material section on each respective base material foil for the corresponding conductive tabs Figure B: Annotated Tajima Figure 2C PNG media_image2.png 371 1063 media_image2.png Greyscale It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have a coated material strip for battery chemical reactions, and exposed material sections, for electrical connection. Claims 3, 13, & 18-20 are rejected under 35 U.S.C. 103 as being unpatentable over US20070218355A1 (Ryu) in view of US20160043363A1 (Tajima), US20210384550A1 (Kumagae), and US20210194041A1 (Park), as applied to claim 1, and further in view of EP4415089A1 (Akbarinia). With regard to claim 3, modified Ryu teaches the limitations of claim 1, as described above. Ryu fails to teach the following limitations of claim 3, which are taught by Akbarinia: stacking the first battery monocell and the second battery monocell additionally includes arranging a first support element in contact with the cathode of the first battery monocell and a second support element in contact with the second separator of the first battery monocell such that the at least one spring element is sandwiched by the first and second support elements Akbarinia describes a spring between batteries for swelling compensation (abstract), and a holding plate 44 or 46 between the spring and each battery cell to uniformly distribute the load (paragraphs 31-33; figure 6). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to put a holding plate between the spring and the battery of modified Ryu, as taught by Akbarinia, for swelling compensation and to uniformly distribute the load. With regard to claim 13, modified Ryu teaches the limitations of claim 11, as described above. Ryu fails to teach the following limitations of claim 13, which are taught by Akbarinia: stacking the first battery monocell and the second battery monocell additionally includes arranging a first support element in contact with the cathode of the first battery monocell and a second support element in contact with the second separator of the first battery monocell such that the at least one spring element is sandwiched by the first and second support elements Akbarinia describes a spring between batteries for swelling compensation (abstract), and a holding plate 44 or 46 between the spring and each battery cell to uniformly distribute the load (paragraphs 31-33; figure 6). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to put a holding plate between the spring and the battery of modified Ryu, as taught by Akbarinia, for swelling compensation and to uniformly distribute the load. Ryu teaches the following claim 18 limitations: A method of manufacturing a lithium-ion (paragraph 23) battery cell comprising: providing a battery cell container (paragraph 38: battery case); generating a first battery monocell having a respective lithium-metal anode, cathode, first separator arranged therebetween, and a second separator arranged adjacent to the corresponding anode (paragraphs 22; Figure A below): generating a second battery monocell having a respective anode, cathode, first separator arranged therebetween, and a second separator arranged adjacent to the corresponding anode (paragraph 22; Figure A below); wherein each cathode of the respective first and second battery monocells is defined by a corresponding outer perimeter (Figure A below)… arranging each cathode in a column (Figure A below)… stacking the first battery monocell and the second battery monocell such that the second separator of the first battery monocell is adjacent to the cathode of the second battery monocell (paragraph 22; Figure A below)… arranging the stacked first and second battery monocells in the battery cell container (paragraph 38: mounting the electrochemical cell in a battery case) Figure A: Annotated Ryu Figure 5 PNG media_image1.png 378 1191 media_image1.png Greyscale Ryu, however, fails to teach the following limitations of claim 18, which are taught by Tajima: wherein generating the first and second battery monocells includes: extracting the respective anodes and cathodes from corresponding electrode material sheets via one of die and laser cutting the respective anodes and cathodes from corresponding electrode material sheets Tajima describes laser cutting the active material layer and current collector, because laser cutting can be performed with a high yield (paragraph 103). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have cut out Ryu’s anodes and cathodes with a laser, as taught by Tajima, for high yield. Ryu, however, fails to teach the following limitations of claim 18, which are taught by Kumagae: wherein generating the first and second battery monocells includes …coating the outer perimeter of each respective cathode (paragraph 76; figures 2B & 6B: positive electrode layer 10A) with an electrically insulating material (paragraphs 63 & 84: insulating material) Ryu, however, fails to teach the following limitations of claim 18, which are taught by Park: stacking the first battery monocell and the second battery monocell includes arranging at least one spring element between the first and second battery monocells Park describes a spring, between lithium-ion cells, to control pressure on the cells (paragraphs 1, 4, & 20). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have a spring between Ryu’s batteries, as taught by Park, for pressure control. Ryu, however, fails to teach the following limitations of claim 18, which are taught by Akbarinia: arranging a first support element in contact with the cathode of the first battery monocell and a second support element in contact with the second separator of the first battery monocell such that the at least one spring element is sandwiched by the first and second support elements Akbarinia describes a spring between batteries for swelling compensation (abstract), and a holding plate 44 or 46 between the spring and each battery cell to uniformly distribute the load (paragraphs 31-33; figure 6). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to put a holding plate between the spring and the battery of modified Ryu, as taught by Akbarinia, for swelling compensation and to uniformly distribute the load. With regard to claim 19, modified Ryu teaches the limitations of claims 18 as described above. Ryu, however, fails to teach the following limitations of claim 19, which are taught by Tajima: wherein generating the first and second battery monocells includes extracting the respective anodes and cathodes via one of die and laser cutting the respective anodes and cathodes from corresponding electrode material sheets (paragraph 103) Tajima describes laser cutting the active material layer and current collector, because laser cutting can be performed with a high yield (paragraph 103). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to have cut out Ryu’s anodes and cathodes with a laser, as taught by Tajima, for high yield. With regard to claim 20, modified Ryu teaches the limitations of claims 18-19 as described above. Ryu also teaches the following limitations of claim 20: the electrode material sheets are constructed from respective anode and cathode material, and wherein generating the first and second battery monocells includes coating the respective electrode material onto a corresponding base material foil (paragraph 37) Claims 9 & 17 are rejected under 35 U.S.C. 103 as being unpatentable over US20070218355A1 (Ryu) in view of US20160043363A1 (Tajima), US20210384550A1 (Kumagae), and US20210194041A1 (Park), as applied to claims 1, 4, 6-7, 11, & 14-15,and further in view of US20190273235A1 (Uematsu). Ryu fails to teach the following limitations of claims 9 & 17, which are taught by Uematsu: generating the first and second battery monocells includes masking each conductive tab prior to coating the outer perimeter of each respective cathode (paragraph 91) It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for modified Ryu’s battery tabs to be masked during manufacture, as taught by Uematsu, so that they won’t be covered with active material, and consequently can make an electrical connection. Conclusion THIS ACTION IS MADE FINAL. 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROBERT WEST whose telephone number is 703-756-1363 and email address is Robert.West@uspto.gov. The examiner can normally be reached Monday-Friday 10 am - 7 pm 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. 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. /R.G.W./Examiner, Art Unit 1721 /ALLISON BOURKE/Supervisory Patent Examiner, Art Unit 1721
Read full office action

Prosecution Timeline

Oct 19, 2023
Application Filed
May 27, 2026
Non-Final Rejection mailed — §103, §112
Jun 29, 2026
Examiner Interview Summary
Jul 06, 2026
Response Filed
Jul 17, 2026
Final Rejection mailed — §103, §112
Aug 17, 2026
Response after Non-Final Action

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Prosecution Projections

2-3
Expected OA Rounds
75%
Grant Probability
99%
With Interview (+24.4%)
3y 3m (~4m remaining)
Median Time to Grant
Moderate
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