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 of Group I (claims 1-12) in the reply filed on August 31, 2026 is acknowledged. Because applicant did not distinctly and specifically point out the supposed errors in the restriction requirement, the election has been treated as an election without traverse (MPEP § 818.01(a)).
Claims 13-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on August 31, 2026.
Claim Objections
Claim 1 objected to because of the following informalities:
"an battery pack interior" (line 2) should recite "a battery pack interior" for purposes of clarity.
Appropriate correction is required.
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 1-7 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Janarthanam et al. (US 2016/0020447).
Regarding Claim 1, Janarthanam et al. teaches a battery pack (Fig. 2, #54) comprising a venting system (Para. [0051]) (i.e. a battery pack venting assembly) comprising an enclosure (Fig. 3, #60) (i.e. battery pack enclosure assembly) providing vent chambers (Fig. 3, #68) (i.e. a battery pack interior), comprising one or more battery arrays (Fig. 2, #56) inside the battery pack including a plurality of stacked battery cells (Fig. 2, #58) (i.e. a plurality of cell stacks within the battery pack interior, each cell stack including a plurality of battery cells), a frame assembly (Fig. 3, #71) of each battery array (Para. [0048]) (i.e. a plurality of module enclosure assemblies within the battery pack interior, each of the module enclosure assemblies housing one or more of the cell stacks), the venting system including tubing (Fig. 4, #76) attached to an end plate of the battery pack and fluidly connects to the vent chamber (Para. [0052]) (i.e. an exhaust trunk extending through the battery pack enclosure assembly form the battery pack interior to an area outside the battery pack interior) and including branches (Fig. 4, #81) each connecting to different vent chambers (Para. [0052]) (i.e. a plurality of exhaust branches within the battery pack interior, each of the exhaust branches extending from one of the module enclosure assemblies to the exhaust trunk).
Regarding Claim 2, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches the [exhaust] branches (Fig. 4, #81) each open to the tubing (i.e. exhaust trunk) (Fig. 4, #76) within the battery pack interior (see Fig. 4).
Regarding Claim 3, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches the exhaust branches of the tubing (Fig. 2, #76) each configured to communicate vent products (Fig. 2, #VP) directly from one of the module enclosures to the exhaust trunk (see Fig. 2).
Regarding Claim 4, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches the tubing attached to an end plate of the battery pack and fluidly connects to the vent chamber (Para. [0052]) wherein the battery vent byproducts flow through the vent chambers and the tubing prior to he being expelled outside the battery pack (Para. [0051]) (i.e. wherein the exhaust trunk is configured to communicate vent byproducts received from one or more of the exhaust branches to the area outside the battery pack enclosure assembly ).
Regarding Claim 5, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches one or seals may seal the vent chambers to avoid mixing vent byproducts with cooling fluid and from an exterior of the enclosure (Para. [0050]) and a check valve that is a one-way valve that permits battery vent byproducts to flow along the venting path out of the battery pack and blocks atmospheric air from entering into the vent chamber (Para. [0053]) via a sealing disk (Para. [0057]) (i.e. wherein the module enclosure assemblies, the exhaust branches, and the exhaust trunk are sealed such that, within the battery pack interior, vent byproducts are contained by the module enclosure assemblies, the exhaust branches, and the exhaust trunk).
Regarding Claim 6, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches a cooling fluid such as a liquid coolant to cool the battery cells of the battery arrays (Para. [0047]) (i.e. wherein the cell stacks are immersion cooled).
However, the limitation of the instant claim is a product by process limitation. The manner in which the product is formed (via immersion cooling) is a product by process limitation which does not further limit the claimed product.
“[E]ven though product-by-process claims are limited by and defined by the process, determination of patentability is based on the product itself. The patentability of a product does not depend on its method of production. If the product in the product-by-process claim is the same as or obvious from a product of the prior art, the claim is unpatentable even though the prior product was made by a different process.” In re Thorpe, 777 F.2d, 698, 227 USPQ 964, 966 (Fed. Cir. 1985)(citations omitted).
“The Patent Office bears a lesser burden of proof in making out a case of prima facie obviousness for product-by-process claims because of their peculiar nature” than when a product is claimed in the conventional fashion. In re Fessmann, 489 F.2d 742, 744, 180 USPQ 324, 326 (CCPA 1974). Once the Examiner provides a rationale tending to show that the claimed product appears to be the same or similar to that of the prior art, although produced by a different process, the burden shifts to applicant to come forward with evidence establishing an unobvious difference between the claimed product and the prior art product. In re Marosi, 710 F.2d 798, 802, 218 USPQ 289, 292 (Fed. Cir. 1983). Ex parte Gray, 10 USPQ2d 1922 (Bd. Pat. App. & Inter. 1989). See MPEP section 2113.
Regarding Claim 7 Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches cooling flow paths (Fig. 2, #66) (i.e. a plurality of coolant inlet branches) wherein a cooling fluid such as liquid coolant is communicated through the coolant flow paths to cool the battery cells of the battery arrays (Para. [0047]) (i.e. each of the coolant inlet branches configured to communicate a liquid coolant to one of the module enclosure assemblies).
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 8-11 are rejected under 35 U.S.C. 103 as being unpatentable over Janarthanam et al. (US 2016/0020447) in view of Hickey (US 2023/0318118).
Regarding Claim 8, Janarthanam et al. teaches all of the elements of the current invention in claim 7 as explained above.
Janarthanam et al. does not teach a coolant inlet trunk that communicates a liquid coolant to each of the plurality of coolant inlet branches.
However, Hickey teaches a coolant inlet conduit (Fig. 4, #248) (i.e. a coolant inlet trunk) that fluidically connects a coolant reservoir to a battery case module (Para. [0038]) wherein a coolant inlet manifold (Fig. 4, #248) connects the coolant reservoir to the battery case (claim 1) (i.e. that communicates a liquid coolant to each of the plurality of coolant inlet branches).
It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the coolant flow passage of Janarthanam et al. to incorporate the teaching of the coolant inlet trunk that communicates a liquid coolant to each of the plurality of coolant inlet branches as taught by Hickey, as such a structure provides more coolant in the thermal management system, improving cooling efficacy and increase in battery capacity (Para. [0007]).
Regarding Claim 9, Janarthanam et al. as modified by Hickey teaches all of the elements of the current invention in claim 8 as explained above.
Janarthanam et al. does not teach the coolant inlet branches are directly connected to the coolant inlet trunk within the battery pack interior
However, Hickey teaches a coolant inlet conduit (Fig. 4, #248) (i.e. a coolant inlet trunk) that fluidically connects a coolant reservoir to a battery case module (Para. [0038]) wherein a coolant inlet manifold (Fig. 4, #248) connects the coolant reservoir to the battery case (claim 1) (i.e. that communicates a liquid coolant to each of the plurality of coolant inlet branches) and they are connected within the protective outer case (see, Fig. 4, #202).
It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the coolant flow passage of Janarthanam et al. to incorporate the teaching of the coolant inlet trunk that communicates a liquid coolant to each of the plurality of coolant inlet branches connected within the battery pack interior as taught by Hickey, as such a structure provides more coolant in the thermal management system, improving cooling efficacy and increase in battery capacity (Para. [0007]).
Regarding Claim 10, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. teaches the exhaust branches of the tubing (Fig. 2, #76) each configured to communicate vent products (Fig. 2, #VP) directly from one of the module enclosures to the exhaust trunk (see Fig. 2) (i.e. the plurality of exhaust branches are configured to communicate vent products directly from one of the module enclosure assemblies to the exhaust trunk).
Janarthanam et al. does not teach wherein the plurality of exhaust branches are configured to communicate liquid coolant and vent byproducts directly from one of the module enclosure assemblies to the exhaust trunk.
However, Hickey teaches exhaust runners (i.e. a plurality of exhaust branches) in which vent gases and liquid immersion cooling [LIC] fluid (i.e. liquid coolant) is allowed to flow into (Para. [0042]) (i.e. a plurality of exhaust branches configured to communicate liquid coolant and vent byproducts).
It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the plurality of exhaust branches of Janarthanam et al. to incorporate the teaching of being configured to communicate liquid coolant and vent byproducts, as such a structure would provide a supplemental exit route that expends LIC fluid (i.e. liquid coolant) and vent gas (i.e. byproducts) thermal energy (Para. [0041]) upon the occurrence of a thermal event preventing violent eruption and mitigating thermal runaway (Para. [0039]).
Regarding Claim 11, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above
Janarthanam et al. does not teach the battery cells are each configured to vent into a liquid coolant.
However, Hickey teaches vent gas are mixed with the LIC fluid (i.e. wherein the battery cells are each configured to vent into a liquid coolant) (Para. [0038], [0039]).
It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery cells of Janarthanam et al. to incorporate the teaching of being configured to vent into a liquid coolant as, taught by Hickey, as such a configuration allows for LIC fluid with entrained gases to be transferred out of the immersion compartment, preventing violent eruptions and mitigating thermal runaway (Para. [0039])
Claim 12 is rejected under 35 U.S.C. 103 as being unpatentable over Janarthanam et al. (US 2016/0020447).
Regarding Claim 12, Janarthanam et al. teaches all of the elements of the current invention in claim 1 as explained above.
Janarthanam et al. further teaches one or seals may seal the vent chambers to avoid mixing vent byproducts with cooling fluid and from an exterior of the enclosure (Para. [0050]) and a check valve that is a one-way valve that permits battery vent byproducts to flow along the venting path out of the battery pack and blocks atmospheric air from entering into the vent chamber (Para. [0053]) via a sealing disk (Para. [0057]) (i.e. a check valve that blocks a backflow of vent byproducts from the exhaust trunk through the exhaust branches). While Janarthanam et al. does not teach a plurality of check valves, a duplication of parts has no patentable significance unless a new and unexpected result is produced. In re Harza 124 USPQ 70 (See MPEP 2144.04 VI. B.). Further, it would be obvious to one of ordinary skill to include a plurality of check valves such as for blocking reverse flow (Para. [0023]), effectively venting/expelling the vent byproducts in case of over-temperature and/or over-current conditions (Para. [0003]).
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ARMINDO CARVALHO JR. whose telephone number is (571)272-5292. The examiner can normally be reached Monday-Thursday 7:30a.m.-5p.m..
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/ARMINDO CARVALHO JR./Primary Examiner, Art Unit 1729
