Prosecution Insights
Last updated: August 30, 2026
Application No. 18/528,143

Battery Modules Having Formed-In-Place Thermal-Management Components, and Methods of Making Such Battery Modules

Non-Final OA §102§103
Filed
Dec 04, 2023
Priority
Nov 07, 2023 — CN 202311476810X
Examiner
SACCUCCI, TREVOR MICHAEL
Art Unit
Tech Center
Assignee
Ses (Shanghai) Co. Ltd.
OA Round
1 (Non-Final)
Grant Probability
Favorable
1-2
OA Rounds

Examiner Intelligence

Grants only 0% of cases
0%
Career Allowance Rate
0 granted / 0 resolved
-60.0% vs TC avg
Minimal +0% lift
Without
With
+0.0%
Interview Lift
resolved cases with interview
Typical timeline
Avg Prosecution
6 currently pending
Career history
1
Total Applications
across all art units

Statute-Specific Performance

§103
50.0%
+10.0% vs TC avg
§102
50.0%
+10.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 0 resolved cases

Office Action

§102 §103
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 . Priority Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). The certified copy has been filed in parent Application No. CN-202311476810-X filed on 11/7/2023. Claim Interpretation Claims 17 and 19 recite “the wall is a bottom wall of the housing...”; this is interpreted here as being any wall comprising the battery module housing recited in Claims 1 or 19. Claim 18 recites a battery module “wherein the housing has a circular transverse cross-sectional shape”; this is interpreted here to include the housings of individual electrochemical cells comprising the battery core, which the battery module comprises. Claim Rejections - 35 USC § 102 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 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. Claims 1-5, 10-13, 17 and 20 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Behm, et al. (U.S. Patent No. 11,398,651 B2). Claim 1: Behm teaches a battery module having a battery module housing which has a multiplicity of housing walls which form an interior space (Fig. 1., Elements 2, 3, and 4; Abstr.); this is interpreted here as “A battery module comprising: a housing that encloses a first interior space” recited in Claim 1. Behm also teaches that the battery module housing may be formed from a first material, in particular a plastic or a multi-component composite material, which is electrically insulative (Fig 1., Elements 2, 3; Col. 2, Lines 52-53, 56-58, 62-66); this is interpreted here as “…the housing having a wall composed of a first dielectric material and having an exterior side…” recited in Claim 1. Behm further teaches that the interior space of the battery module contains a multiplicity of battery cells (Figs. 1-2, Elements 4, 2, 2 22; Abstr.; Col. 7, Lines 64-67); this is interpreted here as “a battery core comprising one or more battery cells” recited in Claim 1. Behm also teaches an embodiment of the battery module with a thermally conductive adhesive, as a pasty or hardening material (Col. 4, Lines 43-45), which is disposed so as to be in direct contact with the multiplicity of battery cells as far as possible to conduct heat away from the battery cells (Col 4, Lines 15-21), and which extends through holes in walls of the housing to form an outer layer disposed over those walls (Figs. 3, 5, Elements 25, 22, 28,26; Col. 9, Lines 4-14, 34); this is interpreted here as “a formed-in-place thermal management component extending through the wall of the housing so that, during use of the battery module, the formed in place thermal management component can conduct heat from the battery core to the exterior side of the wall when the battery core generates the heat” recited in Claim 1. Claim 2: Behm teaches all the limitations of Claim 1. Behm further teaches an embodiment of the battery module where walls of the housing have holes through which the thermally conductive adhesive (Col. 4, Lines 43-45) extends to form an outer layer disposed over those walls (Figs. 3, 5, Elements 25, 22, 28,26; Col. 9, Lines 4-14, 34); this is interpreted here as “[t]he battery module of claim 1, wherein the wall comprises a plurality of apertures, and the formed-in-place thermal management component extends through the wall by way of those apertures” recited in Claim 2. Claim 3: Behm teaches all the limitations of Claim 2. Behm further teaches that the thermally conductive adhesive (Col. 4, Lines 43-45) extends to form an outer layer disposed over those housing walls comprising a plurality of holes (Figs. 3, 5, Elements 25, 22, 28,26; Col. 9, Lines 4-14, 34), and by logical inference over the holes themselves; this is interpreted here as “[t]he battery module of claim 2, wherein the formed-in-place thermal management component has an external portion extending over the plurality of apertures” cited in Claim 3. Claim 4: Behm teaches all the limitations of Claim 3. Behm further teaches that the thermally conductive adhesive, as a pasty or hardening material (Col. 4, Lines 43-45), is disposed so as to be in direct contact with the multiplicity of battery cells as far as possible to conduct heat away from the battery cells (Col 4, Lines 15-21), and extends through holes in walls of the housing to form an outer layer disposed over those walls (Figs. 3, 5, Elements 25, 22, 28,26; Col. 9, Lines 4-14, 34); this adhesive so disposed is referred to by Behm as a compensation element (Col. 3, Lines 61-67), and is interpreted here as “the thermal-management component… composed of a thermal adhesive” recited in Claim 4. Claim 5: Behm teaches all the limitations of Claim 4. Behm further teaches that the thermal compensation element is advantageously formed from an electrically insulating material (Col. 3, Lines 64-67) with a relatively high thermal conductivity (Col. 4, Lines 1-3) which can further adhere to and conduct heat to a cooling element (Col 4., Lines 31-37) formed from a different material with a higher thermal conductivity than the first material comprising the battery module housing (Col. 2, Lines 52-58); this is interpreted here as “the formed-in-place thermal-management component is made of a second dielectric material different from the first dielectric material” recited in Claim 5. Claim 10: Behm teaches all the limitations of Claim 1. Behm further teaches that the thermally conductive adhesive, as a pasty or hardening material (Col. 4, Lines 43-45), is disposed so as to be in direct contact with the multiplicity of battery cells as far as possible to conduct heat away from the battery cells (Col 4, Lines 15-21), and extends through holes in walls of the housing to form an outer layer disposed over the outer surfaces of those walls, with the outermost portion of the thermal adhesive outer layer being disposed above the outer surfaces of those walls (Figs. 3, 5, Elements 25, 22, 28,26; Col. 9, Lines 4-14, 34); this is interpreted here as “the exterior side of the wall [having] an external surface, and the formed-in-place thermal management component [having] an external portion [with] an exterior face spaced from the external surface of the wall” recited in Claim 10. Claim 11: Behm teaches all the limitations of Claim 10. Behm further teaches that the walls of the housing have holes through which the thermally conductive adhesive (Col. 4, Lines 43-45) extends to form an outer layer disposed over those walls (Figs. 3, 5, Elements 25, 22, 28,26; Col. 9, Lines 4-14, 34), and by logical inference over the holes themselves; this is interpreted here as “the wall comprises a plurality of apertures, and the formed-in-place thermal management component extends through the wall by way of a plurality of apertures, and the external portion extends over the plurality of apertures” recited in Claim 11. Claim 12: Behm teaches all the limitations of Claim 1. Behm further teaches that the thermally conductive adhesive, as a pasty or hardening material (Col. 4, Lines 43-45), is disposed so as to be in direct contact with the multiplicity of battery cells as far as possible to conduct heat away from the battery cells (Col 4, Lines 15-21); this is interpreted here as “the formed-in-place thermal management component [which] is adhesively bonded to the battery core” recited in Claim 12. Claim 13: Behm teaches all the limitations of Claim 1. Behm further teaches that the battery module housing has a cuboidal overall basic shape (Figs. 1,3, Element 2, Col. 7, Lines 56-57); this is interpreted here as “the housing has a rectangular transverse cross-sectional shape” recited in Claim 13. Claim 17: Behm teaches all the limitations of Claim 13. Behm further teaches that the bottom of the battery module housing comprises a housing wall (Fig. 1, Elements 2,3; Abstr.); this is interpreted here as “the wall is a bottom of the housing” recited in Claim 17. Claim 20: Behm teaches all the limitations of Claim 1. Behm further teaches an embodiment of the module where the opening on a top side of the module housing can be closed off and sealed with a cover element comprising electrical elements such as cell connectors, or electronics elements such as a circuit board, a control unit or temperature sensors (Fig. 1, Elements 2, 11, 10; Col. 6, Lines 58-68; Col 7, Lines 1-3); this is interpreted here as “the housing encloses a second interior space, and the second interior space includes battery management circuitry in operative communication with the battery core” recited in Claim 20. 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. 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. Claims 6-7 and 14-15 are rejected under 35 U.S.C. 103 as being unpatentable over Behm, and further in view of Tyler, et al. (WO2016167873A1). Claims 6-7: Behm teaches all the limitations of Claim 5. Behm is silent regarding a quantitative value of the thermal conductivity of the second dielectric material. Therefore, one of ordinary skill in the art would have looked to related art to find operative thermal conductivity for the thermal adhesives. Tyler teaches an embodiment of a battery module with an epoxy resin based thermally conductive adhesive which may have a thermal conductivity between 0.5 W/mK and approximately 5 W/mK, which is used to bond a surface of an electrochemical cell to a heat sink in the battery module (Fig. 3, Elements 78, 74, 44, 80, 28; ¶¶ 0041, 0050, 0049). Thus, it would have been obvious to one of ordinary skill in the art at the time of filing to have selected the epoxy resin adhesive of Tyler with a thermal conductivity greater than 0.5 W/mK as the thermally conductive adhesive in Behm because Tyler teaches that 0.5-5 W/mK are operative ranges for the thermal conductivity. Claim 14: Behm teaches all the limitations of Claim 13. Behm is silent as to the use of pouch cells. Tyler teaches a battery module with certain embodiments which may incorporate pouch cells as the electrochemical cells (Fig. 3, Element 44; ¶ 0035). Thus, it would have been obvious to one of ordinary skill at the time of filing to select the pouch cells of Tyler as the electrochemical cells in the battery module of Behm to obtain the predictable result of “the battery core compris[ing] a plurality of battery cells of the pouch type” recited in Claim 14. Claim 15: Behm and Tyler combined teach all the limitations of Claim 14. Behm further teaches the use of lithium ion batteries (Col. 1, Lines 9-12), interpreted here as “each electrochemical cell is a lithium cell” recited in Claim 15. Claims 8-9 are rejected under 35 U.S.C. 103 as being unpatentable over Behm and Tyler, as applied to claim 6, above, and further in view of Obasih, et al. (WO20114106084A1). Claims 8-9: Behm and Tyler combined teach all the limitations of Claim 6. Behm and Tyler are both silent as to numerical values for the thermal conductivity of a battery module housing wall. Therefore, one of ordinary skill in the art would have looked to related art to find operative thermal conductivity for the battery module housing. Obasih teaches an embodiment of a battery module with an electrically non-conductive polymer housing made with unfilled plastic polymers with room temperature thermal conductivities in the range of 0.17 – 0.35 W/mK (Fig.10, Element 44; Table 1; ¶¶ 0037, 0046). Thus, it would have been obvious to one of ordinary skill at the time of filing to have selected one or more of the unfilled polymers of Obasih as the polymer battery module housing material in Behm because Obasih teaches that 0.17 – 0.35 W/mK are operative ranges for the thermal conductivity. Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Behm and Tyler, and further in view of Coowar, et al. (US 2009/0136834A1). Claim 16: Behm and Tyler combined teach all the limitations of Claim 15. Behm and Tyler are both silent as to the use of lithium metal pouch cells. Therefore, one of ordinary skill in the art would have looked to related art to find lithium metal pouch cells. Coowar teaches pouch battery cells with lithium metal anodes (¶¶ 0001, 0015). Thus, it would have been obvious to one of ordinary skill at the time of filing to select the lithium metal pouch cells of Coowar as the electrochemical cells in an embodiment of the battery module of Behm because Coowar teaches pouch cells with lithium metal anodes. Claims 18 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Behm, and further in view of Obasih, et al. (WO20114106084A1). Claim 18: Behm teaches all of the limitations of Claim 1. Behm is silent as to housings with a circular transverse cross-sectional shape. Obasih teaches an embodiment of a battery module comprising cylindrical battery cells with polymer housings (Figs. 9, 6, Elements 24, 44, 92, 96, 13; ¶¶ 53-54, 40). Thus, it would have been obvious to one of ordinary skill at the time of filing to select the cylindrical battery cells with polymer housings taught by Obasih to use in an embodiment of the battery module of Behm to obtain the predictable result of “the housing [having] a circular transverse cross-sectional shape” recited in Claim 18. Claim 19: Behm and Obasih combined teach all the limitations of Claim 18. Behm is silent as to housings with a circular transverse cross-sectional shape where the wall is a bottom wall of the housing. Obasih teaches a battery module comprising cylindrical cells with polymer housings extending to and over the bottom of each cell (Figs. 9, 6, Elements 24, 44, 92, 96, 13; ¶¶ 53-54, 40). Thus, it would have been obvious to one of ordinary skill at the time of filing to select the cylindrical battery cells with polymer housings taught by Obasih to use in the battery module of Behm to obtain the predictable result of “the wall [being] an end wall of the housing” recited in Claim 18. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to TREVOR MICHAEL SACCUCCI whose telephone number is (571)270-1867. The examiner can normally be reached Monday-Friday 8:30 am - 5:00 pm. 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, Michael B Cleveland can be reached at (571)272-1418. 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. /TREVOR MICHAEL SACCUCCI/ Examiner, Art Unit 1712 /MICHAEL B CLEVELAND/ Supervisory Patent Examiner, Art Unit 1712
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Prosecution Timeline

Dec 04, 2023
Application Filed
Aug 04, 2026
Non-Final Rejection mailed — §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
Grant Probability
Low
PTA Risk
Based on 0 resolved cases by this examiner. Grant probability derived from career allowance rate.

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