Prosecution Insights
Last updated: April 19, 2026
Application No. 18/522,370

LITHIUM IRON PHOSPHATE BATTERY CELL END-OF-LINE QUALITY CONTROL PROCESSING

Non-Final OA §101
Filed
Nov 29, 2023
Examiner
SATANOVSKY, ALEXANDER
Art Unit
2857
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
FCA US LLC
OA Round
1 (Non-Final)
56%
Grant Probability
Moderate
1-2
OA Rounds
4y 0m
To Grant
75%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allow Rate
265 granted / 472 resolved
-11.9% vs TC avg
Strong +19% interview lift
Without
With
+18.6%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
53 currently pending
Career history
525
Total Applications
across all art units

Statute-Specific Performance

§101
29.0%
-11.0% vs TC avg
§103
42.4%
+2.4% vs TC avg
§102
3.2%
-36.8% vs TC avg
§112
19.4%
-20.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 472 resolved cases

Office Action

§101
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. DETAILED ACTION Claim Interpretation under 35 U.S.C. 112(f): The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are those that are labeled as “system,” in claims 1 -12, 15-16 . The claims describe various systems in functional terms of what they do, rather than how they do it. Under 35 USC 112(f), the Specification must identify a specific and readily-identifiable algorithm in the Specification associated with the claimed function. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. According to MPEP 2181, II, B, “In cases involving a special purpose computer-implemented means-plus-function limitation, the Federal Circuit has consistently required that the structure be more than simply a general purpose computer or microprocessor and that the specification must disclose an algorithm for performing the claimed function. See, e.g., Noah Systems Inc. v. Intuit Inc., 675 F.3d 1302, 1312, 102 USPQ2d 1410, 1417 (Fed. Cir. 2012); Aristocrat, 521 F.3d at 1333, 86 USPQ2d at 1239. HYPERLINK "https://rdms-mpep-vip.uspto.gov/RDMS/MPEP/ch2100_d222e6_13a14_1cb" … the specification must sufficiently disclose an algorithm to transform a general purpose microprocessor to a special purpose computer so that a person of ordinary skill in the art can implement the disclosed algorithm to achieve the claimed function. Aristocrat, 521 F.3d at 1338, 86 USPQ2d at 1242.” A review of the specification shows that the following appears to be the corresponding algorithm for performing the claimed function as described in the specification for the 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragr aph limitation: functional diagrams in Figs. 2A, 2B, 3C . If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1- 18 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Specifically, representative Claim 1 recites: “ A battery cell end-of-line (EOL) quality processing system for a lithium iron phosphate (LFP) battery system for an electrified vehicle, the battery cell EOL quality processing system comprising: a parameter determination system configured to determine, for each of a plurality of test LFP battery cells, ( i ) a minimum state of charge (SOC) threshold and (ii) a self-discharge rate and a self-discharge rate threshold based on the plurality of self-discharge rates ; a cell quality processing system configured to determine whether each LFP battery cell of the LFP battery system passes a cell quality test based on the minimum SOC threshold, the self-discharge rate threshold, and a self-discharge rate of the LFP battery cell ; and an EOL battery arrangement system configured to keep any of the LFP battery cells of the LFP battery system that pass their respective cell quality tests and to replace any of the LFP battery cells of the LFP battery system that fail their respective cell quality tests to obtain a final EOL LFP battery system . ” The claim limitations in the abstract idea have been highlighted in bold above; the remaining limitations are “additional elements”. Under the Step 1 of the eligibility analysis, we determine whether the claims are to a statutory category by considering whether the claimed subject matter falls within the four statutory categories of patentable subject matter identified by 35 U.S.C. 101: Process, machine, manufacture, or composition of matter. The above claim is considered to be in a statutory category (process). Under the Step 2A, Prong One, we consider whether the claim recites a judicial exception (abstract idea). In the above claim, the highlighted portion constitutes an abstract idea because, under a broadest reasonable interpretation, it recites limitations that fall into/recite an abstract idea exceptions. Specifically, under the 2019 Revised Patent Subject matter Eligibility Guidance, it falls into the groupings of subject matter that covers mathematical concepts - mathematical relationships, mathematical formulas or equations, mathematical calculations and mental processes – concepts performed in the human mind including an observation, evaluation, judgement, and/or opinion. For example, steps of “ determine, for each of a plurality of test LFP battery cells, ( i ) a minimum state of charge (SOC) threshold and (ii) a self-discharge rate and a self-discharge rate threshold based on the plurality of self-discharge rates ” and “ determine, for each of a plurality of test LFP battery cells, ( i ) a minimum state of charge (SOC) threshold and (ii) a self-discharge rate and a self-discharge rate threshold based on the plurality of self-discharge rates ” are treated as belonging to the mathematical concepts grouping while the step of “ to keep any of the LFP battery cells of the LFP battery system that pass their respective cell quality tests and to replace any of the LFP battery cells of the LFP battery system that fail their respective cell quality tests to obtain a final EOL LFP battery system ” is treated as belonging to mental process grouping. Th is mental step represent s a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, and a decision “ to keep any of the LFP battery cells of the LFP battery system that pass their respective cell quality tests and to replace any of the LFP battery cells of the LFP battery system that fail their respective cell quality tests to obtain a final EOL LFP battery system ” in the context of this claim , encompasses a user manually determining whether to keep or replace battery cells based on passing/failing quality tests criteria (observation/evaluation/judgement steps) . Similar limitations comprise the abstract ideas of Claim 10 . Next, under the Step 2A, Prong Two, we consider whether the above claim s that recites a judicial exception are integrated into a practical application. The above claims comprise the following additional elements: In Claim 1: A battery cell end-of-line (EOL) quality processing system for a lithium iron phosphate (LFP) battery system for an electrified vehicle, the battery cell EOL quality processing system comprising: a parameter determination system ; a cell quality processing system ; an EOL battery arrangement system ; In Claim 10 : A battery cell end-of-line (EOL) quality processing method for a lithium iron phosphate (LFP) battery system for an electrified vehicle , a computing system and for each of a plurality of test LFP battery cells ; outputting, by the computing system, instructions . The additional elements in the preamble s are recited in generality and represent insignificant extra-solution activity (field-of-use limitations) that is not meaningful to indicate a practical application. The additional elements in the claims such as (EOL) quality processing system … for an electrified vehicle, a parameter determination system; a cell quality processing system; an EOL battery arrangement system (Claim 1) and computing system (Claim 10) a processor (Claim 1) are examples of generic computer equipment (components) that are generally recited and not meaningful and, therefore, are not qualified as particular machines to indicate a practical application . The limitation that generically recite obtaining final EOL LFP battery system (Claim 1) and outputting instructions (Claim 10) are not meaningful to indicate a practical application and they represent insignificant extra-solution activity. Therefore, the claims are directed to a judicial exception and require further analysis under the Step 2B. However, the above claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception (Step 2B analysis) because these additional elements/steps are well-understood and conventional in the relevant art based on the prior art of record. The independent claims, therefore, are not patent eligible. With regards to the dependent claims, claims 2 - 9 , 11-18 provide additional features/steps which are part of an expanded abstract idea of the independent claims (additionally comprising abstract idea steps) and, therefore, these claims are not eligible without meaningful additional elements that reflect a practical application and/or additional elements that qualify for significantly more for substantially similar reasons as discussed with regards to Claim 1 . For example, additional elements in Claims 9 and 18 (vehicle is eSUV ) are all recited in generality and not meaningful to indicate a practical application and/or qualify for significantly more. Analysis of Closest Prior Art The following references are considered to be the closest prior art to the claimed invention: Xiao Yan et al. ( US 20230208178 ), hereinafter ‘Yan ’, discloses a battery cell end-of-line (EOL) quality processing system for a lithium iron phosphate (LFP) battery system for an electrified vehicle , the battery cell EOL quality processing system comprising: a parameter determination system configured to determine, for each of a plurality of test LFP batteries cells ( A battery management system (BMS) is configured to read a present operation data stream of each cell. A diagnosis apparatus is configured to extract a key battery parameter of said each cell from the present operation data stream and consistency thereof, compare the key battery parameter with historical data to determine whether a battery module fails, Abstract ; FIG. 7 shows a curve of a state of charge (SOC)-open-circuit voltage (OCV) of a lithium iron phosphate cell in Example 2 [0022] ; Fig.3; electric vehicles [0003] ), ( i ) a minimum state of charge (SOC) threshold ( Fig.13; [0067] ) and ( ii) a self-discharge rate ( a self-discharge rate of each cell and the variation trend of the characteristic values with time from the data [0059] ) and a self-discharge rate threshold ( Calculate a resistance, a present capacity, and a self-discharge parameter of each cell by using the battery data … the self-discharge parameter is greater than a self-discharge parameter threshold [0097]) . Yan additionally discloses a cell quality processing system configured to determine whether each LFP battery cell of the LFP battery system passes a cell quality test based on SOC threshold and the self-discharge rate of the LFP battery cell ( The intelligent gateway is configured to store a fault code, fault information, and a charging/discharging control parameter. The fault information includes serious fault information and general fault information. The serious fault information includes a sign of a micro-short circuit, thermal runaway, insulation abnormality, overheating, and communication abnormality, and the characteristic value or the consistency parameter of the battery is equal to or exceeds the safety threshold. The general fault information includes battery undervoltage, battery overvoltage, a low SOC, a high SOC, a balance fault, and the characteristic value or the consistency parameter of the battery exceeding the reliability threshold but less than the safety threshold [0053] ; According to the variation trend of battery characteristic values such as … the capacity, and the self-discharge rate and the consistency thereof with time, the reliability threshold and the safety threshold of the battery characteristic values and the consistency thereof are obtained based on the variation law of the same kind and the same batch of lithium batteries in the aging process. A model describing the variation of the characteristic values with time is established to predict the future development trend of the characteristic values, and the dynamic reliability threshold of the abnormal characteristic values is established [0068]). Yan Zhang et al. ( CN 104316877 ), hereinafter ‘ Zhang ’, discloses a m ethod f or d etecting s elf -d ischarge o f Lithium Iron Phosphate b attery to improve service life of the battery pack . A relationship between l ithium iron phosphate battery SOC and OCV ( corresponding to self-discharge rate , added) is disclosed. Peter Christ Tamburrino et al. ( US 20160020623 ), hereinafter ‘ Tamburrino ’, discloses that preferred state of charge may be selected to extend the shelf-life of the rechargeable batteries as well as self-discharge rate. Haiyu Liao et al., “ Research on a fast detection method of self-discharge of lithium battery ”, Journal of Energy Storage, Volume 55, Part A, November 2022, 8 pages, hereinafter ‘Liao’, https://www.sciencedirect.com/science/article/pii/S2352152X22014232?via%3Dihub discloses using OCV and threshold for the self-discharge rate of each cell to determine capacity loss . Examiner Note with regards to Prior Art of Record Claims 1-18 are distinguish ed over prior art of record for the following reasons: With regards to Claims 1 and 10 , the claim s differ from the closest prior art, Yan, Zhang, Tamburrino , and Liao , either singularly or in combination, because the above references fail to anticipate or render obvious a cell quality processing system configured to determine whether each LFP battery cell of the LFP battery system passes a cell quality test based on the minimum SOC threshold, the self-discharge rate threshold, and a self-discharge rate of the LFP battery cell , in combination with all other limitations in the claim as claimed and defined by applicant. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Xia Li et al. (US 20250341584), hereinafter ‘Li’ discloses a battery cell end-of-line (EOL) quality processing system for a lithium iron phosphate (LFP) battery system for an electrified vehicle comprising a parameter determination system configured to determine, for each of batteries, ( i ) a minimum state of charge (SOC) threshold and (ii) a self-discharge rate. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALEXANDER SATANOVSKY whose telephone number is (571)270-5819 . The examiner can normally be reached on M-F: 9 am-5 pm . If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Catherine Rastovski can be reached on (571) 27 0 - 0349. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. 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, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /ALEXANDER SATANOVSKY/ Primary Examiner, Art Unit 2857
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Prosecution Timeline

Nov 29, 2023
Application Filed
Mar 10, 2026
Non-Final Rejection — §101 (current)

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Prosecution Projections

1-2
Expected OA Rounds
56%
Grant Probability
75%
With Interview (+18.6%)
4y 0m
Median Time to Grant
Low
PTA Risk
Based on 472 resolved cases by this examiner. Grant probability derived from career allow rate.

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