Prosecution Insights
Last updated: October 01, 2026
Application No. 18/519,214

THERMAL MANAGEMENT SYSTEM FOR RECHARGEABLE ENERGY STORAGE SYSTEM

Non-Final OA §102§103§112
Filed
Nov 27, 2023
Examiner
WEI, ZHONGQING
Art Unit
Tech Center
Assignee
GM Global Technology Operations LLC
OA Round
1 (Non-Final)
59%
Grant Probability
Moderate
1-2
OA Rounds
7m
Est. Remaining
74%
With Interview

Examiner Intelligence

Grants 59% of resolved cases
59%
Career Allowance Rate
252 granted / 427 resolved
-1.0% vs TC avg
Moderate +14% lift
Without
With
+14.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
31 currently pending
Career history
467
Total Applications
across all art units

Statute-Specific Performance

§101
0.9%
-39.1% vs TC avg
§103
52.9%
+12.9% vs TC avg
§102
8.7%
-31.3% vs TC avg
§112
31.8%
-8.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 427 resolved cases

Office Action

§102 §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 . Election/Restrictions Applicant's election with traverse of Group I (claims 1-14) in the reply filed on Aug. 11, 2026 is acknowledged. While the election was made with traverse, the Applicant has failed to point out wherein either (1) the reasons advanced by the Examiner to establish distinctiveness between the inventions as claimed and grouped or (2) the evidence of separate status, classification and/or search are in error. Therefore, the restriction requirement is made FINAL. Claims 15-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected invention, there being no allowable generic or linking claim.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 Aug. 11, 2026. Claims 1-14 are being examined on the merits in this office action. Information Disclosure Statement The information disclosure statements (IDS) submitted on Sep. 18, 2024 and Aug. 21, 2026 have been considered by the examiner. 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. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-14 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 1 (line 9) recites the limitation "the thermal management fluid inlet manifold". There is insufficient antecedent basis for this limitation in the claim. For purposes of examination, this recitation is interpreted as referring to the inlet manifold of the thermal management system. Claims 2 and 5 recite the term “selectively”. It is unclear what the difference is when using or not using the term. The scope of claim 2 or claim 5 is thus not ascertainable. The term appears to be redundant. For purposes of examination, the term is interpreted as not limiting the scope of the claim(s). The term “normally” recited in claims 4 and 7 is a relative term which renders the claim indefinite. The term “normally” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. The term “fresh” recited in claim 13 is a relative term which renders the claim indefinite. The term “fresh” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. 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 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 pre-AIA 35 U.S.C. 103(a) which forms the basis for all obviousness rejections set forth in this Office action: (a) A patent may not be obtained through the invention is not identically disclosed or described as set forth in section 102 of this title, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negatived by the manner in which the invention was made. The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under pre-AIA 35 U.S.C. 103(a) 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 under pre-AIA 35 U.S.C. 103(a), the examiner presumes that the subject matter of the various claims was commonly owned at the time any inventions covered therein were made absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and invention dates of each claim that was not commonly owned at the time a later invention was made in order for the examiner to consider the applicability of pre-AIA 35 U.S.C. 103(c) and potential pre-AIA 35 U.S.C. 102(e), (f) or (g) prior art under pre-AIA 35 U.S.C. 103(a). Claim Rejections - 35 USC § 102/103 Claim 1 is rejected under 35 U.S.C. 102(a)(1) or 102(a)(2) as anticipated by or, in the alternative, under 35 U.S.C. 103 as obvious over Bourke et al. (US 20070087266 A1, hereafter Bourke). Regarding claim 1, Bourke teaches a battery system (e.g., title) comprising: a first rechargeable energy storage system (RESS) (monoblock module 101) including a first housing (See, e.g., Figs. 4A-4B); a second RESS (another “101”) including a second housing (See, e.g., Figs. 4A-4B); and a thermal management system (comprising: 114, 136, 112, 137, 115, etc.) fluidically connected to the first RESS and the second RESS (See, e.g., Fig. 1A), wherein the thermal management system comprising: a source of thermal management fluid (One of ordinary skill in the art would readily appreciate that the coolant flowing through flow channel 112 necessarily has a source); an inlet manifold (e.g., right 112 in Figs. 5A-5B) fluidically connected through 114 to the source of thermal management fluid; an outlet manifold (e.g., left 112 in Figs. 5A-5B) including a thermal management fluid outlet (170) fluidically connected to the thermal management fluid inlet manifold (right or left 112) (See at least [0051]); a first thermal management fluid supply conduit (A1-B1) extending through the first RESS, the first thermal management fluid supply conduit including a first end (A1) connected to the inlet manifold and a second end (B2) connected to the first housing; and a second thermal management fluid supply conduit extending through the second RESS, the second thermal management fluid supply conduit including a first end portion (A2) connected to the inlet manifold and a second end portion (B2) connected to the second housing. See the annotated Fig. 5B. PNG media_image1.png 720 1280 media_image1.png Greyscale Claim Rejections - 35 USC § 103 Claims 2-9 are rejected under 35 U.S.C. 103 as being unpatentable over Bourke, as applied to claim 1 above, and further in view of Behlen et al. (US 20200220237 A1, hereafter Behlen). Regarding claims 2-9, Burke teaches the battery system according to claim 1, but appears silent on an inlet valve and an outlet valve as claimed. In the same field of endeavor, however, Behlen discloses a similar battery system comprising multiple battery modules (2), wherein a thermal management system comprises a first inlet valve (e.g., 24 on the right of the upper 2) and a first outlet valve (e.g., the upper 31 in Fig. 2) arranged in a first thermal management fluid supply conduit (See the upper 21 in Fig. 2) to control the temperature of the battery system. It would have been obvious to one of ordinary skill in the art to have incorporated the Behlen’s teachings of temperature control into Bourke such that a first inlet valve arranged and a first outlet valve are arranged in the first thermal management fluid supply conduit at the inlet manifold and at the outlet manifold, respectively so as to control the temperature of the battery system, because the use of known technique to improve similar devices (methods, or products) in the same way is prima facie obvious (MPEP § 2143). As a result, the first inlet valve selectively creates a first passage that fluidically connects the inlet manifold with the outlet manifold through the first RESS (combination of Fig. 5 of Bourke and Fig. 2 of Behlen). Bourke in view of Behlen teaches the first inlet valve is a normally closed valve (check valve 24, [0036]) and the first outlet valve is a normally open valve (“valve element 31 is activated and opened” and “… 31 is configured as a burst valve …”, [0036]). Similar to the first inlet/outlet valve described above, Bourke in view of Behlen further teaches the battery system as modified comprises a second inlet valve (e.g., the lower 21 in Fig. 2 of Behlen) and a second outlet valve (e.g., the lower 31 in Fig. 2) arranged in the second thermal management fluid supply conduit (See, e.g., the lower 21 in Fig. 2 of Behlen) and selectively creating a second passage that fluidically connects the inlet manifold with the outlet manifold through the second RESS (combination of Fig. 5 of Bourke and Fig. 2 of Behlen). Similar to the first inlet/outlet valve described above, the second inlet valve is a normally closed valve and the second outlet valve is a normally open valve. Bourke in view of Behlen teaches the battery system as modified further comprises a first sensor mounted in the first RESS and a second sensor mounted in the second RESS (See 5 in Fig. 2 of Behlen). Bourke in view of Behlen teaches the battery system as modified comprises a control system (control unit 4 in Fig. 2 of Behlen) operatively connected to the first sensor, the second sensor, the first inlet valve and the second inlet valve, the control system selectively opening the first inlet valve and the second inlet valve based on a triggering parameter sensed in the first RESS and the second RESS, respectively (See, at least, [0036]). Claims 10-14 are rejected under 35 U.S.C. 103 as being unpatentable over Bourke, as applied to claim 1 above, and further in view of Houchin-Miller et al. (US 20140093755 A1, hereafter Houchin-Miller). Regarding claims 10-14, Bourke teaches the battery system according to claim 1, but appears silent as to the thermal management fluid comprising water. In the same field of endeavor, however, Houchin-Miller discloses water in a thermal management system (1310) is used as a cooling fluid supplied to battery modules through a pump (See, e.g., [0269], Figs. 65-68). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to have incorporated the teachings of Houchin-Miller into Bourke such that a thermal management system taught by Bourke is used to supply water as the thermal management fluid to the battery system of Bouke, since the use of known technique to improve similar devices (methods, or products) in the same way is prima facie obvious (See MPEP § 2143). As a result, the thermal management system (1310) of Houchin-Miller reads on a container of thermal management fluid, the management system comprises water, a body of water, or a body of fresh water. Furthermore, one of ordinary skill in the art would readily appreciate that water from a water utility can be used as the source of thermal management fluid. Correspondence Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZHONGQING WEI whose telephone number is (571)272-4809. The examiner can normally be reached Mon - Fri 9:30 - 6:00. 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, Barbara Gilliam can be reached at (571)272-1330. 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. /ZHONGQING WEI/Primary Examiner, Art Unit 1727
Read full office action

Prosecution Timeline

Nov 27, 2023
Application Filed
Sep 21, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
59%
Grant Probability
74%
With Interview (+14.5%)
3y 5m (~7m remaining)
Median Time to Grant
Low
PTA Risk
Based on 427 resolved cases by this examiner. Grant probability derived from career allowance rate.

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