Prosecution Insights
Last updated: October 22, 2026
Application No. 18/502,406

BATTERY FLUID CIRCUIT

Non-Final OA §103
Filed
Nov 06, 2023
Examiner
RESTO OQUENDO, NATHALY MARIE
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Deere & Company
OA Round
1 (Non-Final)
50%
Grant Probability
Moderate
1-2
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 50% of resolved cases
50%
Career Allowance Rate
1 granted / 2 resolved
-15.0% vs TC avg
Strong +100% interview lift
Without
With
+100.0%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 0m
Avg Prosecution
22 currently pending
Career history
19
Total Applications
across all art units

Statute-Specific Performance

§103
68.8%
+28.8% vs TC avg
§102
12.5%
-27.5% vs TC avg
§112
12.5%
-27.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 2 resolved cases

Office Action

§103
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 . Claims 1-12 are currently pending and have been considered below. Election/Restrictions Applicants’ election with traverse of 1-8 in the reply filed on September 1, 2026, is acknowledged. The traversal is on the ground(s) that Group I and II share substantial structural and functional subject matter and that the examination of the groups would not impose a serious additional search or examination burden. This is not found persuasive because Claims 1-8 (Group I) are directed to a battery system, whereas claims 9-12 (Group II) are directed to a process of using a battery system. The product of Group 1 can be used in a materially different process from that recited in Group II. In particular, claim 9 requires initiation of circulation of the first fluid after initiation of circulation of the second fluid, whereas claim 1 does not require such sequential operation. Thus, the battery system of Group I may be operated, for example by initiating circulation of the first and second fluids simultaneously or by initiating circulation of the first fluid before the second fluid, neither of which is the process recited of claim 9. Accordingly, the product and process of use are district under MPEP §806.05(h). Further, while the groups share certain structural subject matter, examination of Group I requires searching for the structural arrangement and fluid communication of the claimed battery fluid circuits, whereas examination of Group II additionally requires searching operational methods and control sequences involving sequential circulation of different fluids. Such subject matter requires additional search strategies and queries not required for Group I and therefore presents a serious search burden. See MPEP §803 and §808.02. The requirement is still deemed proper and is therefore made FINAL. Claims 9-12 withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected invention, there being no allowable generic or linking claim. Applicant timely traversed the restriction (election) requirement in the reply filed on September 1, 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. 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. Claims 1-5 and 8 are rejected under 35 U.S.C. 103 as being unpatentable over Frick et al. (US20220158291 A1; hereinafter “Frick”) in view of Björneklett et al. (US20240234871 A1; hereinafter “Björneklett”) and Meyer et al. (US20240258612 A1; hereinafter “Meyer”). Regarding Claim 1: Frick discloses a battery module 40 including a frame 50 disposed within a spacer 80, wherein the frame 50 supports an array 202 of electrochemical cells 200 (A battery system comprising, a cell holder, a plurality of cells disposed in the cell holder) [0093], [0098]-[0099]. Frick further discloses that the cells 200 are cylindrical and elongated along the respective longitudinal axes 212, and that the cells are oriented such that the longitudinal axes are parallel to one another (oriented to be aligned with an axis) [0094], [0099]. Frick further discloses linear grooves 98 formed in the first and second wall portions of spacer, wherein the grooves provide coolant fluid passageways 102 extending from the spacer first end 82 to the spacer second end 84 and facing the cell array 202 (a cell holder fluid circuit formed around and between each of the plurality of cells and extending through the cell holder) [0111], [0129].Frick discloses that the fluid enters the grooves at the spacer first end and exist at the spacer second end (from a cell holder fluid circuit inlet to a cell holder fluid circuit outlet) [0128]. Frick discloses an inlet plenum assembly 502 including an inlet plenum 504, fluid inlet opening 522, and an inlet flow diverter 540 for directing fluid toward the fluid passageways 102, and an outlet plenum assembly including an outlet plenum and an outlet opening 622 for collecting fluid discharged from the fluid passageways [0146]. Frick does not disclose a first end fluid circuit formed by a first channel at an axial end of the plurality of cells comprising a first end fluid circuit inlet and a first end fluid circuit outlet; and a second end fluid circuit formed by a second channel at the axial end of the plurality of cells comprising a second end fluid circuit inlet and a second end fluid circuit outlet. Björneklett discloses a distributor plate disposed between a casing an a plurality of battery cells and a manifold structure comprising a plurality of fluid channels arranged between a fluid entrance and the distributor plate, wherein the fluid channels guide cooling fluid from the fluid entrance to openings in the distributor plate and into spaces between the battery cells (a first end fluid circuit formed by a first channel at an axial end of the plurality of cells comprising a first end fluid circuit inlet and a first end fluid circuit outlet) [0016], [0025]-[0028]. Björneklett further discloses that the battery cells are elongated with their longitudinal axes arranged in parallel, the manifold fluid channels extend in a plane perpendicular to the axes of the battery cells, and the first wall is arranged on one side of the battery cells (first channel at an axial end of the plurality of cells) [0029]. Björneklett further teaches that a cell holder includes through-holes and openings aligned with the distributor plate, so the fluid passes through the holder om the axial; direction into the spaces between the cells [0051]-[0052]. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to provide Frick’s cooling arrangement with the distributor plate and manifold arrangement of Björneklett because Björneklett teaches that the manifold channels improve and even out distribution of cooling fluid over the battery cells, reduce the travel distance of the fluid, reduce pressure drop and improve control of the temperature variation among the cells. See Björneklett [0016], [0026], [0046] and [0049]. This combination does not disclose a second end fluid circuit formed by a second channel at the axial end of the plurality of cells comprising a second end fluid circuit inlet and a second end fluid circuit outlet. Meyer discloses a first fluid channels 111 formed in the first end plate 114 and connected to the interior of the liquid-tight housing 110, through which a first tempering fluid is circulated around the battery cells 120 (a first end fluid circuit) [0099]. Meyer further discloses a second fluid channels 112 formed in the profile housing 113, wherein the second fluid channels are connected to a second fluid channels in the endplates 114, and lead to joint ports 118 connected to a secondary tempering system (a second end fluid circuit formed by a second channel at the axial end of the plurality of cells comprising a second end fluid circuit inlet and a second end fluid circuit outlet) [0101]-[0102]. Meyer further explains that the first and the second tempering fluid systems are spatially separated and are not in fluid communication [0017]. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to further provide the Frick-Björneklett arrangement with the separate second fluid channel system of Meyer because Meyer teaches that the first and the second tempering system exchange heat through the liquid tight housing, improving the thermal coupling and cooling efficiency and also teaches counter-flow of the two tempering fluids to optimize heat transfer. See Meyer [0025], [0103]-[0104]. Regarding Claim 2: Frick et al. in view of Björneklett et al. and Meyer et al. discloses the limitation of claim 1 as set forth above. Björneklett further discloses a manifold structure having fluid channels, wherein at least some of the fluid channels branch into a plurality of narrower channels, the branched channels supplying fluid from a fluid entrance toward an opening in the distributor plate an into spaces between the battery cells (the first end fluid circuit is in fluid communication with the cell holder fluid circuit at a divergence disposed upstream of the plurality of cells) [0035], [0037], [0048]. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to provided Frick-Björneklett-Meyer battery system with the branching manifold arrangement taught by Björneklett because Björneklett teaches that branching and narrowing the channels improves balancing and distribution of the cooling fluid, reduces pressure differences and provides more controlled cooling of the battery cells. See Björneklett [0047]-[0049]. Regarding Claim 3: Frick et al. in view of Björneklett et al. and Meyer et al. discloses the limitation of claim 1 and 2 as set forth above. Björneklett further discloses a fluid entrance arranged in the first wall and a manifold structure having fluid channels extending from the fluid entrance toward openings in the distributor plate, wherein at least some of the fluid channels branch into a plurality of narrower channels (first end fluid circuit inlet comprises the divergence) [0046], [0048]. Thus, the inlet of Björneklett receives a cooling fluid and divides the received flow into multiple downstream flow paths before the fluid entered the spaces between the battery cells. For the same reasons discussed above with respect to claim 2, a person having ordinary skill in the art would have a reason to employ the branching inlet manifold arrangement of Björneklett to improve the distribution of cooling fluid to the battery cells. Regarding Claim 4: Frick et al. in view of Björneklett et al. and Meyer et al. discloses the limitation of claim 1 as set forth above. Björneklett further discloses a collector plate arranged on a side of the battery cels opposite the distributor plate, the collector plate having a plurality of openings configured to receive cooling fluid from spaces between the battery cells, and a second manifold structure comprising a plurality of a second fluid channels arranged to guide the received fluid from the collector plate openings towards a fluid outlet (the first end fluid circuit is in fluid communication with the cell holder fluid circuit at a convergence disposed downstream of the plurality of cells) [0050], Fig. 9. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to employ the downstream collector/manifold arrangement taught by Björneklett in the Frick-Björneklett-Meyer battery system because Björneklett teaches collecting cooling fluid from the spaces between the battery cells and directing the collected fluid toward a fluid outlet, thereby providing an organized return flow path for the cooling fluid. See Björneklett [0046]-[0050]. Regarding Claim 5: Frick et al. in view of Björneklett et al. and Meyer et al. discloses the limitation of claim 1 and 4 as set forth above. Björneklett further discloses a collector plate arranged on a side of the battery cels opposite the distributor plate, the collector plate having a plurality of openings configured to receive cooling fluid from spaces between the battery cells, and a second manifold structure comprising a plurality of a second fluid channels arranged to guide the received fluid from the collector plate openings towards a fluid outlet (the first end fluid circuit outlet comprises the convergence disposed downstream of the plurality of cells) [0050], Fig. 9. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to employ the downstream collector of Björneklett in the battery system of Frick-Björneklett-Meyer because Björneklett teaches that the manifold fluid-channel configuration improves coolant flow and fluid distribution through the battery module. See Björneklett [0046]-[0050]. Regarding Claim 8: Frick et al. in view of Björneklett et al. and Meyer et al. discloses the limitation of claim 1 as set forth above. Meyer further discloses a first tempering fluid contained within the liquid tight housing and in thermal contact with the battery cells, wherein the first tempering fluid is circulated through the interior of the housing and the first fluid channels (wherein the first end fluid circuit and the cell holder fluid circuit are configured to circulate a dielectric fluid) [0010]-[0012]. Meyer discloses that the first tempering fluid may be electrically isolating (dielectric fluid) [0065]. Meyer further discloses a second tempering fluid flowing through a secondary tempering system spatially separated from the first tempering system, wherein the second tempering fluid is not necessarily required to be electrically isolated and may be a mixture of water and glycol (the second end fluid circuit is configured to circulate a non-dielectric fluid) [0013], [0015], [0065]. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to employ the separate first and second tempering fluid systems of Meyer in the battery system of Frick-Björneklett-Meyer because Meyer teaches that such arrangement provides improved temperature control, homogenous cooling of the battery cells, and improved system flexibility by thermally coupling the internal tempering system with the secondary tempering system. See Meyer [0066]. Claims 6 and 7 are rejected under 35 U.S.C. 103 as being unpatentable over Frick et al. (US20220158291 A1; hereinafter “Frick”), Björneklett et al. (US20240234871 A1; hereinafter “Björneklett”) and Meyer et al. (US20240258612 A1; hereinafter “Meyer”) as applied to claim 1 above, and further in view of Totman et al. (US20230378561 A1; hereinafter “Totman”). Regarding Claim 6: Frick et al. in view of Björneklett et al. and Meyer et al. discloses the limitation of claim 1 as set forth above. Frick further discloses a plurality of battery modules, each battery module including a respective frame and spacer supporting a respective array of electrochemical cells, wherein each spacer includes fluid passageways and cooling fluid is permitted to flow throughout the respective battery module, including between the sidewalls of the adjacent cells (a second cell holder, a second plurality of cells disposed in the second cell holder and oriented and a second cell holder fluid circuit formed around and between each of the second plurality of cells and extending through the second cell holder) [0091]-[0092], [0127]. Frick-Björneklett-Meyer do not disclose a second cell holder disposed at an axial side of the first end fluid circuit and the second end fluid circuit opposite from the cell holder. Totman discloses a first cell holder 109 and a second cell holder 110 spaced apart and substantially parallel within the battery module housing 101, together with first cooling channel 901, second cooling channel 902, and middle cooling channel 903 bounded by the first and second cell holders [0047], [0052], [0081]. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery system of Frick-Björneklett-Meyer with the Totman’s spaced cell holder and cooling channel arrangement because Totman teaches that the spacing between the cell holders affects the cooling fluid flow, the flow speed and the pressure, and that adjusting such spacing can improve cooling performance and temperature uniformity within the battery module. See Totman [0072]. Regarding Claim 7: Frick et al., Björneklett et al. and Meyer et al. in view of Totman et al. discloses the limitation of claim 6 as set forth above. Meyer further discloses a first tempering fluid contained within the liquid tight housing and in thermal contact with the battery cells, wherein the first tempering fluid is circulated through the interior of the housing and the first fluid channels (wherein the first end fluid circuit and the cell holder fluid circuit are configured to circulate a dielectric fluid) [0010]-[0012]. Meyer discloses that the first tempering fluid may be electrically isolating (dielectric fluid) [0065]. Meyer further discloses a second tempering fluid flowing through a secondary tempering system spatially separated from the first tempering system, wherein the second tempering fluid is not necessarily required to be electrically isolated and may be a mixture of water and glycol (the second end fluid circuit is configured to circulate a non-dielectric fluid) [0013], [0015], [0065]. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to employ the separate first and second tempering fluid systems of Meyer in the battery system of Frick-Björneklett-Meyer because Meyer teaches that such arrangement provides improved temperature control, homogenous cooling of the battery cells, and improved system flexibility by thermally coupling the internal tempering system with the secondary tempering system. See Meyer [0065]-[0066]. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to NATHALY M RESTO OQUENDO whose telephone number is (571)895-1575. The examiner can normally be reached 8am-5pm. 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, Nicole Buie-Hatcher can be reached at (571) 270-3879. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. 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. /NMRO/Examiner, Art Unit 1725 /NICOLE M. BUIE-HATCHER/Supervisory Patent Examiner, Art Unit 1725
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Prosecution Timeline

Nov 06, 2023
Application Filed
Oct 06, 2026
Non-Final Rejection mailed — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
50%
Grant Probability
99%
With Interview (+100.0%)
2y 0m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 2 resolved cases by this examiner. Grant probability derived from career allowance rate.

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