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 .
Response to Amendment
Applicant's arguments filed July 29, 2026, have been fully considered but they are not persuasive. Based on applicant’s amendments the rejection below has been updated to address the amendments.
Applicant argues that the previously cited Byun and Kim references fail to disclose or suggest an insulating sheet “connected to a lower surface of the lid main body,” wherein “a through hole is formed in a portion of the insulating sheet which overlaps the inversion plate in a height direction,” and wherein the length of the through hole in the electrode-alignment direction is smaller than the length of the low elastic member in that direction.
The Examiner acknowledges that the combination as stated in the previous Office action did not expressly identify a reference teaching the newly added insulating-sheet and through-hole limitations. The rejection has therefore been modified to additionally rely upon Kim 1.
Kim 1 expressly teaches a lower insulation member 59 positioned beneath cap plate 51 and between the cap plate and the internal collector plates. Kim 1 further expressly teaches that the lower insulation member 59 has penetration holes formed at positions corresponding to the first electrode terminal hole, safety vent 57, electrolyte injection part 56a, short-circuit member 60, and second electrode terminal hole 33 (Kim 1 Fig. 2 and 5A-5B).
Moreover, Kim’s short-circuit member 60 is itself pressure-responsive. Kim teaches that deformable part 63 is convex toward the interior of the case in its normal condition and inverts toward the outside of the case when the internal battery pressure exceeds a reference pressure, whereupon it contacts short-circuit extension part 55a and causes a short circuit.
Accordingly, Kim directly demonstrates that it was known before Applicant’s effective filing date to provide a lower insulting member beneath a battery cap plate and to form a penetration opening in that the lower insulating member at the location corresponding to a pressure-responsive short-circuit/inversion structure.
Applicant’s observation that the originally cited references did not disclose such an arrangement therefore does not overcome the rejection as presently modified.
Regarding the relative dimensions of the through hole and low-elastic member, patentability is not established merely by reciting a particular relative dimension where the prior art teaches the corresponding structures and their relative dimensions would have been selected through routine engineering design. The opening must provide adequate clearance and pressure communication for the operation of the inversion structure, while the conductive contact member must provide adequate contact area and structural support. Optimizing those dimensions, including making the opening narrower than the overlying contact member, would have been within the ordinary skill in the art and would have yielded the predictable result of maintaining support around the opening while permitting the pressure-responsive structure to operate.
Applicant further states that the remaining claims are patentable based upon their respective dependencies. This argument is not persuasive because the limitations of the dependent claims have been separately considered below.
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.
Claims 1 and 3-6 are rejected under 35 U.S.C. 103 as being unpatentable over Byun (US 8748030), in view of Kim (US 8999539), hereinafter Kim 1.
Regarding claim 1, Byun teaches a power storage cell comprising an electrode assembly (electrode assembly 110; Fig. 2), a cell case accommodating the electrode assembly (case 140; Figs. 1-2), and an external terminal fixed relative to an upper surface of the cell case (electrode terminals 152, 153; Fig. 2).
Byun teaches that the cell case includes a case main body having an upwardly directed opening and a lid/cap assembly closing the opening (case 140 and cap assembly 150 including cap plate 151; Figs. 1-2; col. 5, lines 10-25).
Byun further teaches that the lid main body is electrically associated with one polarity of the electrode assembly and includes a pressure-responsive short-circuiting structure. Specifically, Byun discloses short-circuiting member 160 including first short-circuiting plate 161 and second short-circuiting plate 162. The first short-circuiting plate 161 is electrically connected to cap plate 151 and includes an inverting portion 161a. The second short-circuiting plate 162 is electrically connected to the opposite electrode terminal. When the internal pressure of the case increases to the predetermined reference pressure, inverting portion 161a inverts and contacts second short-circuiting plate 162, thereby electrically connecting the positive and negative electrode terminals and inducing a short circuit (Byun, col. 6, lines 38-67; col. 7, lines 1-35; Figs. 2 and 3A-3C).
Byun therefore teaches an inversion plate connected to the lid main body and capable of short-circuiting the lid main body and the external terminal.
Byun further teaches that first short-circuiting plate 161 includes an inverting portion 161a and an edge portion 161b surrounding and supporting the inverting portion. Edge portion 161b is fixed to the cap plate 151 around the short-circuiting hole 151c (Byun, Fig. 3A-3C and col. 7, lines 27-35). The edge portion therefore corresponds to the claimed base portion connected to the lid main body and surrounding the inversion portion.
Regarding the claimed annular configuration of the base portion, Byun teaches an edge portion extending around the pressure-responsive inverting portion and fixed around the periphery of the short-circuiting opening. The precise annular geometry of the base portion would have been an obvious configuration for a peripheral support surrounding a generally round pressure-responsive inversion portion. Forming the peripheral supporting portion continuously around the inversion portion provides uniform attachment and pressure loading and constitutes no more than a predictable geometric configuration of the disclosed peripheral edge portion.
Byun further teaches that inverting portion 161a is connected inwardly of edge portion 161b. In the normal condition, the inverting portion projects toward the interior of the battery, i.e., away from second short-circuiting plate 162/external terminal. When internal pressure reaches the predetermined pressure, the inverting portion reverses curvature and projects upwardly toward second short-circuiting plate 162, thereby contacting the second short-circuiting plate (Byun, col. 7, lines 1-27 and Figs. 3A and 3C).
Thus, Byun expressly teaches the presently amended limitation that the inversion portion has a shape curved so as to be convex in a direction away from the external terminal when the internal pressure is below a predetermined pressure and is invertible to have a shape curved so as to be convex toward the external terminal when the internal pressure becomes equal to or higher than the predetermined pressure.
Regarding the low-elastic member, as discussed in the previous Office action, Byun teaches a conductive short-circuiting structure whose portions are selected and configured to accommodate elastic deformation during the inversion operation. Byun expressly explains that flexibility of the inverting portion can be controlled, including through the configuration of the edge region and notch, so that inversion occurs at a desired internal pressure (Byun, col. 7 and the embodiments of Figs. 3A-6B).
To the extent Byun does not expressly identify a separately named conductive low-elastic member disposed on the surface of the inversion portion, it would have been obvious to provide a relatively compliant conductive contact portion on the terminal-facing surface of the inversion portion. Such a member predictably deforms when compressed between the inversion portion and the opposed terminal, thereby increasing the effective electrical contact area and reducing contact resistance. The use of a relatively compliant conductive contact layer represents the predictable use of known conductive-contact structures according to their established function.
The amended claim additionally recites an insulating sheet provided in the cell case, connected to a lower surface of the lid main body, and having a through hole in a portion overlapping the inversion plate in the height direction.
Byun teaches a lower insulation member 159b disposed beneath cap plate 151 between the cap plate and the internal current-collecting structures to prevent undesired electrical shorting. (Byun, Fig. 2).
However, Byun does not expressly disclose that its lower insulation member includes a through hole at the portion overlapping the pressure-responsive short-circuiting member.
Kim 1 teaches precisely such a configuration in an analogous secondary battery safety structure.
Kim 1 teaches a secondary battery having an electrode assembly 10, case 40, cap plate 51, first and second electrode terminals 52 and 53, a pressure-responsive short-circuit member 60, and a lower insulation member 59 positioned directly below the cap plate 51 ( Kim 1, Figs. 1-2).
Kim 1 expressly teaches that lower insulation member 59 is positioned between cap plate 51 and first and second collector plates 20 and 30. Kim 1 further expressly teaches that lower insulation member 59 includes penetration holes formed at positions corresponding to the first electrode terminal hole 24, safety vent 57, electrolyte injection part 56a, short-circuit member 60, and second electrode terminal hole 33 (Kim 1, description corresponding to Figs. 2 and 5A-5B).
Kim 1's short-circuit member 60 includes deformable part 63, which is convex toward the inside of the case in the normal condition and is inverted toward the outside of the case when internal gas pressure exceeds a reference pressure. Upon inversion, deformable part 63 contacts short-circuit extension part 55a to cause the safety short circuit. Thus, the penetration hole in lower insulation member 59 corresponding to short-circuit member 60 is a penetration opening formed in the portion of the lower insulating member that overlaps the pressure-responsive short-circuit structure in the height direction.
Byun and Kim 1 are considered analogous art to the claimed invention because they are in the same field of secondary batteries having cap assemblies and pressure-responsive short-circuit safety mechanisms that respond to increased internal battery pressure.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to configure the lower insulation member of Byun in accordance with Kim 1 by providing penetration openings at the portions corresponding to the components passing through or operating at the cap plate, including the pressure-responsive short-circuit/inversion structure. Kim 1 teaches that this arrangement permits the insulating member to extend along the lower side of the cap plate while providing clearance for the safety vent, electrolyte injection structure, electrode terminals, and pressure-responsive short-circuit member. Such modification would preserve electrical insulation between the cap plate and the internal conductive components while providing the openings necessary for the respective cap-mounted components to operate or communicate through the insulating member.
One of ordinary skill would have had a reasonable expectation of success because both references employ the same general arrangement of a prismatic secondary battery having a case, a cap plate, terminals, lower insulation structure, and a pressure-responsive short-circuit safety device.
Regarding the limitation that the length of the through hole in the alignment direction of the positive and negative electrode members is smaller than a length of the low-elastic member in that direction, neither Byun nor Kim 1 expressly identifies the dimensions using Applicant's particular comparative terminology.
However, selection of the dimensions of the clearance opening relative to the overlying pressure-responsive contact member would have been an obvious matter of routine design and optimization. The opening need only be sufficiently large to permit the pressure-responsive portion to communicate with the interior pressure and move without interference, while the conductive contact portion may extend beyond the opening to provide adequate support and contact area. A person of ordinary skill would have routinely selected the relative dimensions of the opening and contact member according to the desired support area, pressure-responsive area, mechanical strength, and electrical contact area. Making the through hole smaller in the alignment direction than the low-elastic contact member would have been one of a finite number of predictable dimensional relationships and would predictably leave the conductive member supported beyond the boundary of the opening. No criticality or unexpected result arising solely from the claimed dimensional relationship is apparent.
Regarding claim 3, Byun and Kim 1 teaches the limitations of claim 1, as stated above. Kim 1 further teaches a cap plate 51 having penetration openings through which first electrode terminal 52 and second electrode terminal 53 extend. Kim teaches that the first and second terminals are electrically connected to respective first and second collector plates and extend through the cap plate (Kim 1, Fig. 1-2 and the descriptions of cap assembly 50).
Kim 1 further teaches first and second upper insulation member 58a and 58b and gaskets G surrounding the respective terminal structures and electrically insulating the terminals from cap plate 51. Kim explains that the first upper insulation member 58a is positioned between first electrode terminal 52 and cap plate 51 and insulates the first electrode terminal from the cap plate. Likewise, second upper insulation member 58b electrically insulates second electrode terminal 53 from cap plate 51.
Kim 1 therefore teaches separate positive-side and negative-side insulating structures disposed at respective terminal insertion openings and surrounding the respective terminal/coupling structures.
To the extent Kim does not expressly characterize each insulating structure as “cylindrical,” forming an insulating gasket or sleeve surrounding a generally cylindrical terminal or coupling pin in a cylindrical configuration would have been an obvious matter of design dictated by the shape of the member being insulated. A cylindrical sleeve surrounding a cylindrical pin provides substantially uniform electrical isolation around the circumference of the pin and constitutes a predictable configuration for a terminal insulator.
Byun and Kim 1 are considered analogous art to the claimed invention because they are in the same field of secondary batteries having cap assemblies and pressure-responsive short-circuit safety mechanisms that respond to increased internal battery pressure.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to incorporate such terminal-surrounding insulating members into the modified Byun battery to electrical isolate the coupling/terminal structure from the conductive lid while permitting the coupling structures to pass through the lid.
Regarding claim 4, Byun and Kim 1 teach the limitations of claim 1, as stated above. Kim 1 expressly teaches that the cap plate 51 includes a safety vent 57, an electrolyte injection part 56a, first and second electrode terminal openings, and a press-responsive short-circuit member 60.
Kim 1, further expressly teaches that lower insulation member 59 includes penetration holes at positions corresponding to the first electrode terminal hole 24, safety vent 57, electrolyte injection part 56a, short-circuit member 60, and second electrode terminal hole 33.
Thus, Kim 1 teaches an insulating member disposed beneath the lid having respective through holes overlapping, in the height direction, the pressure-release structure, liquid/electrolyte injection structure, and terminal insertion structures.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to configure the lower insulation member of Byun in accordance with Kim because providing corresponding openings allows a continuous lower insulating member to electrically isolate the internal conductive structures from the cap plate while permitting the safety vent, electrolyte injection opening, terminal structures, and press-responsive short-circuit structure to remain unobstructed.
Regarding claim 5, Byun and Kim 1 teach the limitations of claim 4, as stated above. Kim 1 further teaches separate insulation structures associated with the first and second electrode terminals. The first and second upper insulation members 58a and 58b electrically isolate the corresponding terminal structures from cap plate 51, and gaskets G surround the terminal portions passing through the cap plate.
Byun and Kim 1 are considered analogous art to the claimed invention because they are in the same field of secondary batteries having cap assemblies and pressure-responsive short-circuit safety mechanisms that respond to increased internal battery pressure.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to configure these insulating structures as cylindrical sleeves surround the respective positive and negative coupling pins where the coupling pins are cylindrical. Such a configuration merely conforms the insulating member to the shape of the member being insulated and provides predictable circumferential electrical isolation.
Regarding claim 6, Byun and Kim 1 teach the limitations of claim 5, as stated above. Claim 6 further recites that a length from an edge of the low-elastic member to a central axis of the inversion portion is half of the length from an edge of the inversion portion to the central axis in a width direction.
The particular radial or widthwise extent of a compliant conductive contact member on the inversion portion would have been a matter of routine optimization according to the desired electrical contact area, mechanical flexibility, material usage, and pressure-responsive characteristics of the inversion plate.
Once a compliant conductive contact member is provided on the terminal-facing surface of the inversion portion, a person of ordinary skill would have routinely varied its width relative to the inversion portion to obtain sufficient contact area while retaining sufficient uncovered inversion-plate area to permit the desired elastic deformation. Selecting a contact-member extent equal to one-half of the corresponding inversion-portion extent represents a predictable selection within a finite range of possible dimensions and does not alter the basic operating principle of the device.
Absent evidence that the claimed one-half relationship produces an unexpected result or represents a critical value, selecting that particular relative dimension would have been within the ordinary skill in the art.
Claims 2 and 7 are rejected under 35 U.S.C. 103 as being unpatentable over Byun (US 8748030), in view of Kim 1, and in further view of Kim (US 20140193696), hereinafter Kim 2.
Regarding claim 2, Byun and Kim 1 teach the limitations of claim 1, as stated above.
Byun further teaches a battery safety structure including a short-circuiting member (short circuiting member 160) comprising an inversion portion (inversion portion 161 a). The short-circuiting member is formed of conductive material (Col 6 line 38-40). As discussed above the inversion portion of Byun corresponds to the claimed inversion portion and low elastic member. However, Byun does not explicitly disclose that the low elastic member (i.e., the short-circuiting member and inversion portion) is made of tin plating. Kim teaches the use of tin plating in battery components to improve corrosion resistance and maintain electrical conductivity over time ([0081], [0087]).
Byun, Kim 1, and Kim 2 are considered analogous art to the claimed invention because they are in the same field of batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to form the short-circuiting plates of Byun with tin plating as taught by Kim 2 in order to enhance corrosion resistance and ensure reliable electrical performance. Such a modification represents the predictable use of a known material for its known purpose.
Regarding claim 7, Byun and Kim 1 teach the limitations of claim 6, as stated above.
Claim 7 further recites that the low-elastic member is made of tin plating and that the inversion portion is made of aluminum of iron.
Byun expressly teaches that the first short-circuiting plate 161, including inverting portion 161a, may be formed of a conductive material such as aluminum ([0025]).
Alternatively, the use of iron for a pressure-responsive conductive plate would have constituted a known alternative conductive structural material, with the material selected according to the desired elastic modulus, strength, manufacturability, and inversion pressure. Kim 2, as discussed above regarding claim 2, teaches tin plating for conductive battery component to provide corrosion resistance and maintain electrical conductivity ([0081], [0087]).
Byun, Kim 1, and Kim 2 are considered analogous art to the claimed invention because they are in the same field of batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to employ tin plating for the conductive contact member of the modified Byun inversion structure while retaining Byun’s aluminum inversion plate because the combination predictably provides a conductive, corrosion resistant contact surface on a structurally suitable pressure-responsive metal inversion member.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, 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 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 Tamara Orduna whose telephone number is (571)431-1457. The examiner can normally be reached Mon-Fri 8:00-5:00 EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Jennifer Dieterle can be reached at (571) 270-7872. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/TAMARA ORDUNA/Examiner, Art Unit 1776
/Jennifer Dieterle/Supervisory Patent Examiner, Art Unit 1776
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