DETAILED ACTION
Notice to Applicant
In the amendment dated 2026-07-09, the following has occurred: Claims 1-7 and 9 have been amended; Claims 8 has been canceled; Claims 10-15 have been added.
Claims 1-7 and 9-15 are pending and are examined herein. This is a Final Rejection.
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Note on Claim Interpretation
The new limitation “wherein the at least one intermediate space is aligned with the inlet and outlet openings of the housing” does not appear in the specification as written. Support appears to come from instant Fig. 4, which shows a highly schematic diagram with arrows, presumably indicating fluid paths along a plurality of intermediate spaces, that flow from right to left. The phrase “aligned with the inlet and outlet openings of the housing” is interpreted broadly to mean the inlet and outlet are upstream and downstream, respectively, of a circulating flow path, because the specification does not describe what is meant by “alignment” and the drawings do not show sufficient positive structure to narrow the meaning of “alignment” beyond that.
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.
Claims 12 and 13 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention. Claim 12 appears to require space structures that abut opposite sides of the same cell, rather than neighboring first and second cells. This is ambiguous, and at least one reading appears contrary to the instant disclosure. It has been interpreted broadly as requiring a complementary fit between two adjacent cells. Claim 13 requires a “bifurcation” of a stream into more than two streams. It is unclear how this is supposed to work: serial bifurcation, or whether trifurcation is meant. Claim 13 has been interpreted broadly to require a stream that splits to pass through multiple openings in a manifold.
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:
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.
Claim(s) 1-7 and 9-15 are rejected under 35 U.S.C. 103 as being unpatentable over Robert (US 10,476,045 to Robert et al.) in view of Nagamine (US Patent No. 8,691,415 to Nagamine et al.).
Regarding Claim 1, Robert teaches:
a vehicle battery formed from a plurality of battery cells arrayed in a module or stack, with module housing components such as endplates (column 3, lines 65-70, column 5 lines 39-49)
each battery cell in a case 62 including a first side wall and a second wall that is parallel to the first, wherein the plurality of battery cells are stacked within the module housing in such that the second side wall of a first battery cell abuts the first side wall of an adjacent battery cell (Fig. 4, etc.)
a projecting spacer structure 90 which is formed by one of the side walls and is disposed on an outer side of the first side wall and/or an outer side of the second side wall (columns 5-6, Figs. 7 and 9)
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wherein the intermediate spaces or gaps, G, between the spacing structures are coolant passages for either air or a coolant liquid (column 6, line 58)
Robert therefore teaches embodiments with circulating fluid coolant, which would require some sort of recirculation system, well-understood by one of ordinary skill in the art. Any such system would require a closed housing (to contain the fluid) and an inlet and an outlet for the fluid to circulate. While Robert does not explicitly disclose the structure of a closed housing with liquid cooling circulation system. Nagamine, however, from the same field of invention, regarding a battery module for a vehicle, teaches providing a housing that accommodates a battery stack, the battery stack having channels between adjacent cells for flowing coolant (Fig. 1, abstract).
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Nagamine further teaches that the coolant can be gas or liquid (column 5, lines 38-39). Nagamine teaches an inlet and outlet that form a U-shaped path wherein the coolant passes through passages between cells. Under a broadest reasoning of “an inlet/outlet opening,” the opening includes the entire manifold above or below the cell stack, which is “aligned” with the intermediate passages insofar as the manifold interfaces with each one.
Furthermore, the location of the inlet and outlet were known to be ordinary design variables, and could be placed anywhere along the opposite sides of the inter-cool cooling passages, with various results-effective tradeoffs in terms of siting the fluid supply lines and/or changing the cooling profile along the stack. Rearranging and/or duplicating parts has been found to be obvious. See In re Japikse, 181 F.2d 1019, 86 USPQ 70 (CPPA 1950) and In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960). Mere duplication of parts has no patentable significance unless a new and unexpected result is produced, while rearrangement of known parts is obvious when the device operates in the same fashion towards the same purpose. See MPEP 2144.04, VI [R-6]. For further evidence of ordinary skill in the art regarding such schemes, see US Patent No. 3,745,048 to Dinkler et al. and US 2006/0115716 to Kim et al.
Regarding Claim 2, Robert teaches:
a plurality of parallel ribs 90 (Figs. 4, 7, and 9)
Regarding Claim 3, Robert teaches:
wherein the ribs extend parallel to a longitudinal axis of the battery cell (Fig. 4)
Regarding Claim 4, Robert teaches:
the ribs being disposed on both outer sides of the side walls (Figs.)
Regarding Claim 5, Robert teaches:
ribs on the two walls being parallel to each other, and in parallel projection, the ribs on either side wall are offset, such the two spacer structures in a parallel projection onto a projection plane feature ribs on the first side located between ribs on the second (Figs. 7, 9)
Regarding Claim 6, Robert teaches:
wherein the two side walls are both composed of metal (column 4 line 40)
Regarding Claim 7, Robert teaches:
a single extruded profile (column 4 lines 36-41)
Regarding Claim 9, Robert teaches:
a vehicle (abstract, column 1)
Regarding Claim 10, Robert teaches:
a plurality of intermediate spaces (Figs.)
Regarding Claim 11, Robert teaches:
a variety of space shapes
Where a prior art component has the same function as the instantly claimed component, motivation to alter the shape of the component to any other equally useful shape is obvious to one of ordinary skill in the art absent evidence of new or unexpected results. See MPEP 2144.04 IV. In the instant case, it would be obvious to one of ordinary skill in the art to alter the shape of the intermediate spaces, since Robert teaches a variety of shapes, subject to ordinary design choice. It further would have been obvious as a way of flattening temperature profiles, as was conventional in the art for heat exchangers.
Regarding Claim 12, Robert teaches:
spacers on first/second sidewalls that abut second/first sidewalls of a neighboring cell (Fig. 9)
Regarding Claims 13 and 14, Robert teaches:
cells with separate streams, that would necessarily require a separation of an inlet stream into multiple parts, that recombine to exit through the outlet of a closed loop
Nagamine further renders obvious a manifold that divides into streams that pass around cells. and are collected in an outlet manifold. See the figures. Manifolds were conventional in liquid cooling systems.
Regarding Claim 15, Robert teaches:
stacking orthogonal to the flow direction (see Fig. 9, etc.)
Response to Arguments
Applicant’s arguments have been fully considered but do not place the application in condition for allowance. Applicant argues for a narrow “alignment” that distinguishes over Robert. “Alignment” and its cognates are not found anywhere in the specification. Instant 4, which Applicant relies upon for supporting the instant amendment, is described as a “schematic diagram” in the specification, and its “alignment” does not actually correspond to any of the more detailed embodiments. It is not clear that a true “alignment” in the narrow sense that Applicant appears to argue for was contemplated or described in the specification. The claim has been interpreted broadly as a fluid alignment of a manifold and a series of intermediate passages between cells. New art is relied upon for more explicitly teaching a housing with a manifold for circulating liquid, although the Office notes that this structure is basically implied by Robert, even if not described.
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 Michael Dignan, whose telephone number is (571) 272-6425. The examiner can normally be reached from Monday to Friday between 10 AM and 6:30 PM. If any attempt to reach the examiner by telephone is unsuccessful, the examiner’s supervisor, Tiffany Legette, can be reached at (571)270-7078. Another resource that is available to applicants is the Patent Application Information Retrieval (PAIR). Information regarding the status of an application can be obtained from the (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAX. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, please feel free to contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). Applicants are invited to contact the Office to schedule an in-person interview to discuss and resolve the issues set forth in this Office Action. Although an interview is not required, the Office believes that an interview can be of use to resolve any issues related to a patent application in an efficient and prompt manner.
/MICHAEL L DIGNAN/Examiner, Art Unit 1723
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