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 without traverse of claims 1-12 in the reply filed on 07/31/2026 is acknowledged.
Claim 13-17 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim.
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 1-12 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 contains the limitation “the core comprising Li1+xMn1-yAyP1-zRzO4”. The type of atoms which correspond to “R” are not currently defined in the claim and it is therefore unclear what the scope of “R” can be. As such, the metes and bounds of the claims are indefinite.
Claims 2-12 are rejected as being dependent on claim 1.
Claims 2-3 are further rejected due to the limitations “wherein a ratio of y to 1-y in the core ranges from 1:10 to 1:1” and “wherein a ratio of z to 1-z in the core ranges from 1:9 to 1:999”. A value of “y” according to claim 2 ranges from 0.5 to 0.91 to satisfy the ratio requirement: y/(1-y) = 1 means y= 0.5 and y/(1-y) = 10 means y = 10/11 which is about 0.91. A value of “z” in claim 3 ranges from 0.9 to 0.999 (z/(1-z) = 9 means z = 0.9 and z/(1-z) = 999 means z = 0.999). The range of 0.5-0.9 for y is therefore includes a range portion outside the range of 0.001 to 0.600 in claim 1 and the range for z of 0.9 to 0.999, from which claims 2 and 3 depend.
The claim(s) are considered indefinite because there is a question or doubt as to whether the feature introduced by such narrower language is (a) merely exemplary of the remainder of the claim, and therefore not required, or (b) a required feature of the claims.
The following is a quotation of 35 U.S.C. 112(d):
(d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers.
The following is a quotation of pre-AIA 35 U.S.C. 112, fourth paragraph:
Subject to the following paragraph [i.e., the fifth paragraph of pre-AIA 35 U.S.C. 112], a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers.
Claims 2-3 are rejected under 35 U.S.C. 112(d) or pre-AIA 35 U.S.C. 112, 4th paragraph, as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, or for failing to include all the limitations of the claim upon which it depends.
Claims 2-3 contain range limitations for “y” and “z” which lie outside the range in independent claim 1, from which these claims depend. The claims therefore fail to further limit the range of “y” and “z” in claim 1.
Applicant may cancel the claim(s), amend the claim(s) to place the claim(s) in proper dependent form, rewrite the claim(s) in independent form, or present a sufficient showing that the dependent claim(s) complies with the statutory requirements.
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:
Determining the scope and contents of the prior art.
Ascertaining the differences between the prior art and the claims at issue.
Resolving the level of ordinary skill in the pertinent art.
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 1-3, 5, 8-9 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Ohira et al. (U.S. App. Pub. No. 2013/0209886) in view of Chen et al. (CN 114256448A, citation from machine translation filed on 04/30/2025) and Pullen et al. (U.S. App. Pub. No. 2020/0235389).
Regarding claims 1-3, Ohira et al. teaches a cathode active material powder (Abstract and par. [0088], [0092], [0096] and [0097])) having a general formula:
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Which overlaps with the ranges for the composition of claim 1 where Li subscript is 1, x (equivalent to y in claim) is more than 0 and less than equal to 0.5, M can be Zr, Sn or Al, y (equivalent to z in claim 1) is more than 0 and less than 0.5 and R is selected to be Si. As set forth in MPEP 2144.05, in the case where the claimed range “overlap or lie inside ranges disclosed by the prior art”, a prima facie case of obviousness exists, In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990).
Ohira et al. further teaches that the cathode active material particle can be provided with an outer surface coating of carbon to enhance the conductivity of the active material. (par. [0050]). Ohira et al. therefore teaches a core/shell structure including a carbon layer, as claimed.
Ohira et al. does not teach a first and second coating layer, the first coating layer covering the core and a second coating layer covering the first coating layer, wherein: the first coating layer comprises a crystalline pyrophosphate LiaMP2O7 and/or Mb(P2O7)c and a crystalline oxide M′dOe-, wherein: a is greater than 0 and less than or equal to 2; b is any value between 1 to 4; c is any value between 1 and 3, d is greater than 0 and less than 2, e is greater than 0 and less than 5, M is one or more elements selected from Fe, Ni, Mg, Co, Cu, Zn, Ti, Ag, Zr, Nb, and Al; and M' is one or more elements selected from alkali metals, alkaline earth metals, transition metals, group IIIA elements, group IVA elements, lanthanides, and Sb.
Chen teaches a lithium manganese iron phosphate composite material comprising an inner core 10 and a cladding/coating layer 20 covering the inner core, wherein the cladding layer includes at least one barrier material layer 21 and at least one lithium manganese iron phosphate layer 22 (page 3, lines 16–20; Fig. 1). Chen teaches that the barrier material layer may comprise materials selected from metal oxides, metaphosphates, and pyrophosphates (page 2, lines 10-11; page 4, lines 52-60). Chen further teaches that the barrier material layer blocks self-diffusion of manganese caused by differences in manganese content between inner and outer layers, facilitates a differential distribution of manganese, avoids direct contact between the electrolyte and manganese, and suppresses dissolution of manganese (page 4, lines 52–55). Chen specifically teaches metal oxides including aluminum oxide (page 4, lines 56-57). Chen explains that such metal oxides have good stability and are conducive to forming a long-term stable coating of the inner core, thereby providing the lithium manganese iron phosphate composite material with long-term high-efficiency performance and service life (page 4, lines 56–60). Chen's disclosure of aluminum oxide (Al2O3) corresponds to the claimed oxide M′bOc, wherein M′= Al from group IIIA, b=2, and c=3. Chen also teaches pyrophosphate barrier materials, thereby teaching the use of both metal oxide and pyrophosphate materials as barrier/coating materials for a lithium manganese iron phosphate active-material core (page 2, lines 10-11; page 4, lines 52-60).
Chen further teaches providing a carbon coating layer over the composite material (page 2, lines 6–7). Chen explains that the carbon coating layer improves electrical conductivity of the lithium manganese iron phosphate composite material and ensures charge-discharge performance (page 6, lines 58-60). Thus, Chen provides express teaching of an arrangement in which a protective barrier/cladding structure is provided on the active-material core and a carbon coating is subsequently provided over the composite material.
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the positive electrode active material of Ohira to include the protective barrier/coating structure of pyrophosphate layer and oxide layer, taught by Chen between Ohira's active-material core and carbon coating to protect the active material by reducing manganese dissolution and direct electrolyte contact and to provide stability and long-term performance (page 4, lines 52-60). A person of ordinary skill therefore would have been motivated to incorporate Chen's barrier layer into Ohira's coated active material to obtain these expressly taught protective and stability benefits, while retaining the outer carbon coating to provide the conductivity benefits taught by both Wu and Chen.
The resulting structure from the combination of Ohira and Chen et al. would therefore result in a cathode material having the core of Ohira with a protective barrier sequence of layers including pyrophosphates and aluminum oxide, consistent with the limitations of the “first coating layer” and “second coating layer” as claimed.
Ohira as modified by Chen, however, does not teach specifically a crystalline pyrophosphate MaP2O7, wherein: a is greater than 0 and less than or equal to 4; and M is one or more elements selected from Li, Fe, Ni, Mg, Co, Cu, Zn, Ti, Ag, Zr, Nb, and Al. Furthermore, Wu et al. does not explicitly mention that the oxide layer is crystalline.
Pullen et al. teaches a cathode active material having a general composition of Li1+xMO2+y (Abstract and par. [0006]) having a protective coating on the surface thereof of amorphous or crystalline materials including metal phosphates, pyrophosphates and metal oxides of metals such as Al and Ti. (par. [0078]).
It would have been obvious to one of ordinary skill in the art to use crystalline pyrophosphates and oxides of Al or Ti for the multiple coating/cladding material layers disclosed in the combination of Ohira in view of Chen et al.
One of ordinary skill in the art would have found it obvious to use crystalline metal pyrophospahtes and oxides in view of the teachings of Pullen et al. that such materials are known to provide protective properties to lithium metal oxide based cathode materials. The the selection of a known material based on its suitability for its intended purpose is prima facie obvious. MPEP 2144.07.
Regarding claim 5, Chen further teaches the limitation wherein a coating amount of the first coating layer is greater than 0% by weight and less than or equal to 7% by weight.
Chen teaches that the barrier material accounts for 0.3%–0.6% of the mass of the core material (page 8, lines 5-8). Chen further teaches that the barrier material layer is formed on and coats the inner core by solid-phase sintering (page 8, lines 10-22). Chen teaches that using the disclosed amount facilitates complete coating of the inner core during solid-phase sintering, thereby improving the overall performance of the lithium manganese iron phosphate composite material (page 8, lines 5–14). Thus, Chen's disclosed coating amount of 0.3%–0.6% falls within the claimed range of greater than 0% by weight and less than or equal to 7% by weight. It has been held that in the case where claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. See MPEP 2144.05 I.
Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to employ Chen's disclosed amount of barrier material in the first coating layer of the modified Ohira et al. material to facilitate complete coating of the inner core during solid-phase sintering, thereby improving the overall performance of the lithium manganese iron phosphate composite material (Chen page 8, lines 5-14).
Regarding claim 8, given that the value of Mn and P subscripts overlaps with the presently claimed range, the content by weight for the manganese and the phosphorus would overlap with the presently claimed range.
Regarding claim 9, it is the position of the Office that the active material of modified Wu intrinsically satisfies the claimed conditions, given that the structure and material compositions used in the prior art (as applied above to arrive at the rejection of claim 1) and the claimed invention are substantially the same, see MPEP 2112.01.
Regarding claim 12, it is the position of the Office that the active material of modified Wu intrinsically satisfies the claimed conditions, given that the structure and material compositions used in the prior art (as applied above to arrive at the rejection of claim 1) and the claimed invention are substantially the same, see MPEP 2112.01.
Claims 4 is rejected under 35 U.S.C. 103 as being unpatentable over Ohira et al. (U.S. App. Pub. No. 2013/0209886) in view of Chen et al. (CN 114256448A, citation from machine translation filed on 04/30/2025) and Pullen et al. (U.S. App. Pub. No. 2020/0235389), further in view of Visbal et al. (U.S. App. Pub. No. 2015/0118574)
Ohira in view of Chen and Pullen et al. is relied upon as described in the rejection of claim 1, above.
Ohira in view of Chen and Pullen et al. does not disclose that the carbon material for enhancing conductivity includes both sp2 and sp3 carbon.
Visbal et al. teaches a positive electrode for lithium ion battery include a positive electrode particle having an amorphous carbonaceous layer on the surface thereof. (Abstract). Visbal et al. further teaches that the carbon layer includes both sp2 and sp3 carbon bonds. (par. [0068]).
It would have been obvious to one of ordinary skill in the art to use a carbon coating material including both sp2 and sp3 bonds as the carbon coating material in Ohira in view of Chen and Pullen et al.
One of ordinary skill in the art would have found it obvious to use a carbon coating material including both sp2 and sp3 carbon is known as a coating material for a lithium ion cathode particle to prevent unwanted reactions between the positive electrode material and the solid electrolyte (par. [0067]-[0068]). One of ordinary skill in the art would therefore have found it obvious to use a similar material for the carbon coating of Ohira et al. to obtain similar properties and benefits.
Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Ohira et al. (U.S. App. Pub. No. 2013/0209886) in view of Chen et al. (CN 114256448A, citation from machine translation filed on 04/30/2025) and Pullen et al. (U.S. App. Pub. No. 2020/0235389), further in view of Wu (U.S. App. Pub. No. 2016/0190584).
Ohira in view of Chen and Pullen et al. is relied upon as described in the rejection of claim 1, above.
Ohira in view of Chen and Pullen et al. does not disclose a thickness of the first, second or third coating in the ranges claimed.
Wu teaches a Li-ion battery positive electrode material having the general formula:
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And includes a carbon coating on the surface thereof. (Abstract, par. [0005] and par. [0010]). Wu teaches that the carbon coating layer content and thickness can be adjusted by one of ordinary skill in the art but generally has a thickness of 1-10 nm. (par. [0012]).
It would have been obvious to one of ordinary skill in the art to optimize the thickness of the carbon coating of the positive electrode material in Ohira et al. to have a thickness in the range of 1-10nm as disclosed in Wu et al.
One of ordinary skill in the art would have found it obvious to optimize the thickness of the carbon coating in view of the disclosed result effective nature of the content and thickness of the carbon coating on the Li-ion positive electrode material for improving the properties thereof. "Where the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation." In re Aller, 220 F.2d 454, 456 (CCPA 1955). MPEP 2144.05 (II).
Claims 7 is rejected under 35 U.S.C. 103 as being unpatentable over Ohira et al. (U.S. App. Pub. No. 2013/0209886) in view of Chen et al. (CN 114256448A, citation from machine translation filed on 04/30/2025) and Pullen et al. (U.S. App. Pub. No. 2020/0235389), further in view of Hu et al. (CN 108511715, citation from machine translation provided on 05/13/2025).
Ohira in view of Chen and Pullen et al. are relied upon as described in the rejection of claim 1, above.
Ohira in view of Chen and Pullen et al. does not teach an interplanar spacing of 0.293–0.326 nm, and an included angle of 26.41°–32.57° for a [111] crystal orientation.
Hu et al. teaches controlling the annealing conditions to improve the crystal-phase purity of the lithium pyrophosphate coating and to obtain a relatively pure crystalline coating material (page 4, lines 16-22). Hu further teaches that a coating material having a good crystalline phase stabilizes the crystal structure, prevents the active material from directly contacting the electrolyte, inhibits interfacial reactions on the surface of the material, and promotes lithium-ion diffusion and interfacial charge transfer (page 5, lines 7-14).
Hu therefore recognizes the crystallinity of the pyrophosphate coating as a result-effective variable, because Hu expressly teaches controlling annealing conditions to improve crystal-phase purity and further identifies the beneficial structural and electrochemical effects resulting from a coating having a good crystalline phase. Accordingly, the annealing conditions and resulting crystallinity of the pyrophosphate coating could be adjusted to obtain a desired crystalline pyrophosphate coating having beneficial structural properties.
Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to optimize the annealing conditions of the modified Ohira et al. material so as to optimize the crystallinity and crystal-phase purity of the pyrophosphate coating in order to obtain benefits of improved crystal-structure stability, reduced direct contact between the active material and electrolyte, reduced interfacial reactions, and improved lithium-ion diffusion and interfacial charge transfer (Hu page 5, lines 7-14). Where the modified prior-art material comprises the same crystalline pyrophosphate coating as recited in claim 1 and is prepared under conditions selected to obtain the crystalline phase taught by Hu, the interplanar spacing and included angle associated with the [111] crystal orientation are intrinsic crystallographic properties of that crystalline material. Thus, absent evidence demonstrating that the substantially identical crystalline pyrophosphate possesses different crystallographic properties, the claimed interplanar spacing of 0.293–0.326 nm and included angle of 26.41°–32.57° would be inherently satisfied by the resulting crystalline pyrophosphate, see MPEP 2112.01. Moreover, Discovering the optimum or workable ranges of a result-effective variable (i.e., optimal crystalline properties to achieve above-cited beneficial results) involves only routine skill in the art. See MPEP 2144.05(II)
Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Ohira et al. (U.S. App. Pub. No. 2013/0209886) in view of Chen et al. (CN 114256448A, citation from machine translation filed on 04/30/2025) and Pullen et al. (U.S. App. Pub. No. 2020/0235389), further in view of Gardiner et al. ("Anti-site defects and ion migration in the LiFe0.5Mn0.5PO4 mixed-metal cathode material.", 2010, Chemistry of Materials, 22.3, 1242-1248.)
Ohira in view of Chen and Pullen et al. are relied upon as described in the rejection of claim 1, above.
Ohira in view of Chen and Pullen et al. does not teach the Li/Mn anti-site defect concentration in the range presently claimed.
Gardiner teaches antisite defects in the mixed-metal olivine cathode material LiFe0.5 Mn0.5PO4. Gardiner teaches that the Li/M antisite pair, wherein M is Fe or Mn, is the most favorable intrinsic defect in LiFe0.5 Mn0.5PO4 and that, even at low temperatures, a small percentage of approximately 1% of Fe or Mn ions is expected to occupy Li sites (page 1245, section 3.1). Gardiner further concludes that a small population of less than 2% of Li+ and Fe2+ or Mn2+ ions is expected to exchange sites (page 1247, section 4). Gardiner further teaches that such antisite defects impede lithium-ion diffusion to varying degrees along the [010] channels (abstract, page 1247). Accordingly, Gardiner teaches Li/transition-metal antisite defects, including Li/Mn antisite defects, at concentrations falling within the claimed upper limit of 5.1%. It has been held that in the case where claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. See MPEP 2144.05 I.
Further, modified Ohira et al. and Gardiner are considered to be analogous to the claimed invention because both are in the same field of lithium manganese iron phosphate positive electrode active materials.
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the modified Ohira et al. positive active material with a low Li/Mn antisite defect concentration as taught by Gardiner in order to reduce impediments to lithium-ion diffusion and facilitate lithium-ion transport (abstract, page 1247).
Claims 11 is rejected under 35 U.S.C. 103 as being unpatentable over Ohira et al. (U.S. App. Pub. No. 2013/0209886) in view of Chen et al. (CN 114256448A, citation from machine translation filed on 04/30/2025) and Pullen et al. (U.S. App. Pub. No. 2020/0235389), further in view of Xu (CN 106816582 A, citation from machine translation included in this office action).
Ohira in view of Chen and Pullen et al. is relied upon as described in the rejection of claim 1, above.
Ohira in view of Chen and Pullen et al. does not disclose wherein a compacted density of the positive electrode active material under 3 tons is 2.0 g/cm3 or more.
Xu teaches a lithium manganese iron phosphate-based positive electrode material and expressly recognizes compaction density as a property of the material (page 3, lines 20-32). Xu teaches that controlling the particle size of the primary and secondary particles improves particle agglomeration and increases the compaction density of the material (page 5, lines 33-42) and thereby increasing the standby time of the battery (page 1, lines 57-59; page 2, lines 1-2). Xu further teaches optimizing particle size and cohesion to improve the compaction density of the material (page 3, lines 20-32), and teaches a preferred compaction density of 2.0-2.68 g/cm³, more preferably 2.2-2.55 g/cm³ (page 3, lines 39-43). Xu further provides a method for determining compaction density by pressing a sample at 2 MPa and calculating the density based on the measured thickness and volume (page 8, lines 20-25). Thus, Xu expressly recognizes compaction density as a result-effective variable and also teaches values overlapping the claimed range. It has been held that in the case where claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. See MPEP 2144.05 I.
Moreover, it would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to optimize the particle size and cohesion of the modified Ohira et al. material so as to obtain a compacted density of 2.0 g/cm³ or more, because Xu expressly teaches that optimization of particle size and cohesion improves compaction density and that increased compaction density is advantageous for improving the volumetric energy density of the lithium battery and ensuring electrode density (page 3, lines 29-43). Discovering the optimum or workable ranges of a result-effective variable involves only routine skill in the art. See MPEP 2144.05(II). Therefore, when subjected to the same pressure conditions of 3 tons as instantly claimed (which is a product-by-process limitation), the resultant active material of modified Wu would also be expected to exhibit the compacted density of 2.0 g/cm³ or more.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALEXANDRE F FERRE whose telephone number is (571)270-5763. The examiner can normally be reached M-F: 8 am to 4 pm ET.
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/ALEXANDRE F FERRE/Primary Examiner, Art Unit 1788 10/11/2026
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