Prosecution Insights
Last updated: August 17, 2026
Application No. 18/535,947

BATTERY MODULE

Final Rejection §103
Filed
Dec 11, 2023
Priority
Dec 28, 2022 — RE 10-2022-0187202
Examiner
CHOI, EVERETT TIMOTHY
Art Unit
1751
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Samsung SDI Co., Ltd.
OA Round
4 (Final)
12%
Grant Probability
At Risk
5-6
OA Rounds
11m
Est. Remaining
-2%
With Interview

Examiner Intelligence

Grants only 12% of cases
12%
Career Allowance Rate
2 granted / 17 resolved
-53.2% vs TC avg
Minimal -14% lift
Without
With
+-14.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
41 currently pending
Career history
73
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
61.6%
+21.6% vs TC avg
§102
23.8%
-16.2% vs TC avg
§112
10.3%
-29.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 17 resolved cases

Office Action

§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 . Status of Claims Applicant’s amendment and arguments filed 06/11/2026 have been fully considered. Claim(s) 1 is/are amended; claim(s) 7-9 remain withdrawn. Examiner affirms that the original disclosure provides adequate support for the amendment. Upon considering said amendment and arguments, the previous rejection(s) under 35 U.S.C. 103 set forth in the Office action mailed 03/12/2026 has/have been maintained for the reasons presented below. Claim Objections Claim 1 has been objected to for failing to accurately depict the changes made. Claim 1 has been amended in the current set of claims, but the status identifier of claim 1 is currently indicated as (Previously Presented). The status identifier (Currently Amended) should be recited; claim 1 is interpreted as being identified as such. See MPEP 714 II C. Appropriate correction is required. Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claim(s) 1, 10-13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bennet (US20070068686A1) in view of Jiang et al. (WO2022012449A1 cited 12/11/2023 IDS, machine translation in 05/09/2025 Office action). Regarding claim(s) 1 and 10-13, Bennet discloses a battery module (FIG. 21) comprising a housing (2112, “battery enclosure”), and a plurality of battery cells (2116) inside the housing (2112) and arranged in a first (horizontal) direction ([0091-0092], FIG. 21). Bennet further discloses a hazard control system (100), an embodiment thereof being configured to respond to a fire by discharging fire-extinguishing agent (104) and being recognized as a fire-extinguishing sheet ([0087], FIGs. 1, 2, 20.). However, Bennet fails to disclose the battery module with this fire-extinguishing sheet, the embodiment of the hazard control system (100, 2110) in the battery module instead configured to neutralize chemical leakage ([0091-0092], FIG. 21). Jiang is directed to an analogous battery module (100, “fire extinguishing device”, Jiang [0044], FIG. 1). Jiang teaches that battery modules pose risks of thermal runaway, necessitating a means of extinguishing a battery fire ([0004-0005]). Addressing this problem, Jiang teaches disposing a fire-extinguishing sheet (10, “fire extinguishing device housing”) on vents (330, “safety valve”) of battery cells (310, 320) ([0045], FIG. 1). During thermal runaway, the gas released from the battery cell vents (330) melts an insulating film (131) of the fire-extinguishing sheet (10), causing it to release a fire extinguishing agent (110) to quickly and efficiently extinguish fires ([0045-0048], [0050], FIGs. 1, 2). As such, a skilled artisan would recognize the utility of controlling potential fire hazards of Bennet’s battery module, and it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to provide a fire-extinguishing sheet as the hazard control system inside Bennet’s battery module housing as taught by Jiang. Such a modification would be made with a reasonable expectation of success, being within Bennet’s scope of use of the hazard control system to extinguish fire (Bennet [0049]). It would further be obvious to improve the speed and efficacy of extinguishing the fire by providing modified Bennet’s battery cells with vents and providing the fire-extinguishing sheet inside the housing and covering the vents of the battery cells as taught by Jiang. Such a modification would be made with a reasonable expectation of success, as Bennet discloses a suitability of placing the hazard control system (e.g., the fire-extinguishing sheet) adjacent or above (i.e., covering) the hazard source (Bennet [0076]). Modified Bennet further discloses the fire-extinguishing sheet (100) comprises a main body portion (112, “core”) comprising a lightweight, rigid material, where aluminum and Nomex are named as suitable materials (Bennet [0048], FIGs. 1, 2). As Bennet suggests a finite set of materials for the main body portion including aluminum (a metal) inter alia, which share the characteristic of being lightweight and rigid, it would be obvious for one having ordinary skill in the art to routinely explore the selection of aluminum for the main body portion (MPEP 2143 I. E). In doing so, a skilled artisan thus forms the main body portion as a metal plate extending in the first (horizontal) direction (Bennet [0048], FIGs. 1, 2) as claimed in claim 1, where the main body portion is made of aluminum as claimed in claim 10. PNG media_image1.png 369 1057 media_image1.png Greyscale Annotated Bennet FIGs. 1-2 Bennet further discloses the main body portion comprises a plurality of pores (“compartments”) extending between first and second surfaces thereof in a second direction perpendicular to the first direction (see Annotated Bennet FIGs. 1, 2 above; [0048]), and a fire-extinguishing agent (104, “control material”) accommodated within the pores ([0049]) as claimed in claim 1. An insulating film (106, “face sheet”) covers the first and second surfaces of the main body portion (112) and fixes the fire-extinguishing agent (104) within the pores ([0047-0048]; see Annotated Bennet FIGs. 1, 2 above). In embodiments of Bennet’s hazard control system configured to function as a fire-extinguishing sheet, the insulating film (“face sheet”) is configured to rupture in response to fire to release the fire-extinguishing agent (104) ([0088-0089]), the rupturing performed through causing the insulating film to crack from thermal stresses, melting the sheet, peeling back the sheet, or otherwise causing the sheet to move aside upon heat exposure ([0088]). As Bennet suggests this finite set of mechanisms to rupture insulating film, it would be obvious for one having ordinary skill in the art to routinely explore selecting a mechanism of causing the insulating film to melt in response to a fire among the plurality of battery cells as claimed in claim 1 (MPEP 2143 I. E). Bennet discloses a need to select an appropriate material for the insulating film (106) configured to react to a trigger event (e.g., a fire) and rupture (e.g., by melting) to release the fire-extinguishing agent (104) ([0045]). Plastic is named as one such material inter alia from a finite set of materials suitably configurable to rupture in reaction to a trigger event ([0045]), such that it would be obvious for one having ordinary skill in the art to routinely explore selecting plastic as the material of insulating film (106) as claimed in claim 12 for this purpose (MPEP 2143 I. E). However, Bennet fails to further specify the insulating film comprises polyethylene terephthalate (PET), polycarbonate (PC), and polypropylene (PP) as claimed in claim 11, or further specify a melting point of the plastic as claimed in claim 12 where a threshold is 300 °C or less. Jiang teaches a fire-extinguishing sheet (10) which further comprises the structure of a first supporting film layer (131, analogous to Bennet’s insulating film) and a sealing film layer (133) which together fix a fire-extinguishing agent (110) within a sealed space (Jiang [0051], FIG. 2) and melt in response to a fire among the battery cells (i.e., a thermal event), rupturing to release the agent (110) ([0050, 0052], FIG. 2). Jiang further teaches the selection of PE and PC having a melting point of 70-110 °C as a plastic film material of the first supporting film layer (131) to provide this function ([0050]). Therefore, in order to form Bennet’s insulating film with a capability to melt in response to a fire among the battery cells and rupture to release the fire-extinguishing agent, it would be obvious for a skilled artisan to select at least PC as a plastic material of the insulating film as claimed in claim 11, and to select a melting point of 70-110 °C for the plastic material of the insulating film which reads on claim 12’s threshold of a melting point of 300 °C or less as taught by Jiang. Such a selection would be made with a reasonable expectation of success, being within the scope of Bennet’s disclosure of using plastic for the insulating film which melts in response to fire (MPEP 2144.07). In this structure, modified Bennet’s main body portion (an aluminum plate) which forms the pores accommodating the fire-extinguishing agent has a significantly higher melting point (660 °C for aluminum metal) than the insulating film with a melting point of 70-110 °C; therefore, the pores would remain (i.e., are configured to remain) after the insulating film melts, thus creating a gas discharge passage as claimed in claim 1. Bennet is compatible with this structure of main body portion; in the trigger mechanisms of Bennet’s fire-extinguishing sheet, Bennet only requires the insulating film (“face sheet”) to crack, melt, peel back, or otherwise move aside in order to discharge the fire-extinguishing agent (“control material”) [0088], and thus does not necessarily or inherently require destruction of the main body portion and the pores in order to discharge the fire-extinguishing agent. PNG media_image2.png 1240 1981 media_image2.png Greyscale Annotated Jiang FIG. 1 While modified Bennett fails to explicitly indicate that the vents of the battery cells face toward the fire-extinguishing sheet in the second direction (i.e., perpendicular to the first stacking direction) as claimed in claim 13, a skilled artisan would recognize that facing the battery cell vents in the first (stacking) direction would cause the cells to vent into each other instead of the fire-extinguishing sheet, rendering the function of the fire-extinguishing sheet inoperable (see Annotated Jiang FIG. 1 above). Claim(s) 4, 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bennet (US20070068686A1) in view of Jiang (WO2022012449A1) as applied to claim 1, further in view of Yamazaki (WO2021149778A1, machine translation in 03/12/2026 Office action Regarding claim(s) 4, 5, modified Bennet discloses the battery module as claimed in claim 1, but fails to explicitly indicate a mass of fire-extinguishing agent as claimed in claim 4 where a mass of the fire-extinguishing agent is in a range of 35 g/m3 to 100 g/m3 based on a volume of the battery cells, or a thickness of the main body portion as claimed in claim 5 where the main body portion has a thickness in a range of 0.1 mm to 5 mm. Yamazaki is directed to an analogous fire-extinguishing sheet (20, “fire extinguishing element”) containing a main body portion (1, “fire-agent containing layer”) accommodating a fire-extinguishing agent (Yamazaki [0009], [0021], FIG. 3) usable in a battery module ([0039]). Yamazaki teaches increasing the amount of extinguishing agent improves the extinguishing speed and efficacy of the fire-extinguishing sheet, but this requires a larger volume to and may limit the space available for the fire-extinguishing sheet ([0030]). While Yamazaki fails to numerically indicate a mass ratio of fire-extinguishing agent to battery cell volume, a skilled artisan would need to select at least some weight of fire extinguishing agent relative to some volume of battery cells such that it would be obvious to optimize the mass ratio thereof in modified Bennet’s battery module according to Yamazaki’s teachings, and in doing so, reasonably utilize at least a portion of the claimed range of 35-100 g/m3 as claimed in claim 4 (MPEP 2144.05 II). Yamazaki further teaches optimizing the amount of fire-extinguishing agent through varying the main body portion thickness within a suggested range of 30-1000 µm (0.03-1 mm) ([0030]). As such, in seeking to optimize the amount of extinguishing agent, it would likewise be obvious for one having ordinary skill in the art to optimize a thickness modified Bennet’s main body portion within a thickness of 0.03-1mm, overlapping with a portion of the claimed range (0.1-5mm, claim 5) between 0.1-1mm such that a skilled artisan would have selected within the overlap through routine optimization under Yamazaki’s teaching with a reasonable expectation of success (MPEP 2144.05 II). Claim(s) 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bennet (US20070068686A1) in view of Jiang (WO2022012449A1) as applied to claim 1, further in view of Paik et al. (The strength characteristics of aluminum honeycomb sandwich panels; copy in 03/12/2026 Office action) Regarding claim(s) 6, modified Bennet discloses the battery module as claimed in claim 1. Bennet’s main body portion (112) is provided as an aluminum honeycomb having a plurality of compartments (i.e., pores) (Bennet [0048], FIGs. 1, 2), which comprises at least some degree of porosity between 0% to 100%; while Bennet describes the main body portion (112) as being both lightweight and rigid, necessitating some balance between these properties ([0048]), Bennet fails to teach optimizing a porosity of the main body portion to achieve this or numerically indicate a porosity between 50% to 95%. Paik, directed to mechanical considerations of a honeycomb-cored panel composite analogous to Bennet’s main body portion (Paik P207/¶3, P210 FIGs. 2-3), teaches that modifying the cell size and wall thickness to increase a density of the main body portion improves the strength at the expense of weight per unit volume (i.e., density) (P229/¶2, P228 FIGs. 21-22). Paik does not numerically indicate a porosity range of the main body portion, but a skilled artisan would recognize that these changes to cell size and wall thickness would affect the ratio of wall material volume to open space, i.e., the porosity (P210 FIGs. 2-3) alongside the weight of the main body portion. As such, in seeking to balance the weight and rigidity of modified Bennet’s main body portion, it would be obvious for one having ordinary skill in the art to optimize the porosity through varying the cell size and wall thickness of the main body portion as taught by Paik in a range of at least 0-100%, encompassing the range of 50-95% claimed in claim 6 such that a skilled artisan would have selected within the encompassed range through routine optimization under Paik’s teaching with a reasonable expectation of success (MPEP 2144.05 II). Response to Arguments Applicant's arguments filed 06/11/2026 have been fully considered but they are not persuasive for the reasons below: Claim 1 has been amended to recite, inter alia, “a main body portion as a metal plate…having a plurality of pores…, a fire-extinguishing agent accommodated within the pores; and an insulating film covering the first and second surfaces of the main body portion and fixing the fire-extinguishing agent within the pores, wherein the insulating film is configured to melt in response to a fire among the plurality of battery cells, and the pores are configured to remain after the insulating film melts to create a gas discharge passage”. Applicant cites FIGs. 3A, 3B of the instant application to illustrate aspects of the amended claim 1. Applicant asserts that Bennet is expressly directed toward a housing that is designed to completely disintegrate upon exposure to an event such has an impact or fire, citing an embodiment in ¶[0044] of Bennet where “the housing 102 may comprise a container configured to shatter, explode, or otherwise deteriorate, either entirely or in part, upon impact to release the control material 104” and includes a material “designed to shatter upon impact” (Remarks p. 6). For this reason, Bennet does not disclose that “the pores are configured to remain after the insulating film melts to create a gas discharge passage” as amended in claim 1. Modifications to Bennet’s housing to have this feature would also require strengthening the housing, contrary to its intended purpose of shattering or exploding (Remarks p. 7). Examiner notes that Bennet’s disclosed “housing (102)” refers to “any suitable apparatus for containing the control material 104 (i.e., the fire-extinguishing agent) and facilitating dispersal of the control material 104 in response to the trigger event” (Bennet [0044]), which includes the insulating film (106, “face sheets”) ([0045]) and main body portion (112, “core”) ([0048]), but which does not include the control material (104) (Bennet FIGs. 1, 2). Because the instant claims do not recite limitations of a structure consisting of the main body portion and insulating film, Bennet’s housing (102) is not mapped onto any claimed structure or limitation in the rejection of record. However, as discussed here regarding Applicant’s remarks, the housing (102) is interpreted as referring to the insulating film (106) alongside the main body portion (112) comprising the plurality of pores. While Applicant’s argument has been fully considered, it has not been found persuasive. The embodiment of Bennet ¶[0044] cited by Applicant is a specific embodiment configured to respond to impact as a trigger event, not a thermal event such as fire, which necessitates a different mechanism to respond to a different trigger event. For a hazard control system configured to respond to a thermal trigger event ([0087]), i.e., a fire-extinguishing sheet, Bennet envisions one mechanism where the housing (specifically, “the face sheets”, i.e., insulating film) cracks and fractures to trigger discharge of a fire-extinguishing agent, but also envisions mechanisms wherein “the face sheet may melt, peel back, or otherwise move aside upon exposure to heat” ([0088]). These are distinct mechanisms from the mechanism cited by Applicant to respond to an impact as a trigger event in ¶[0045], moreover, these mechanisms require only the insulating film (“face sheets”) to shatter or deteriorate. Thus, none of the trigger mechanisms Bennet discloses or suggests for a fire-extinguishing sheet require the entire housing (i.e., the insulating film and main body portion comprising the pores) to shatter, explode, or otherwise deteriorate, and is thus compatible with claim 1’s structure where the pores [of the main body portion] are configured to remain after the insulating film melts to create a gas discharge passage. Furthermore, of the materials Bennet suggests for the main body portion (112), namely, aluminum or alternatively Nomex ([0048]), Nomex is itself a heat- and flame-resistant textile. The fact that Bennet suggests a fire-resistant material for the main body portion would suggest that Bennet envisions, or is at least compatible with, a main body portion (and the accompanying pores) which is comparatively resistant to a thermal event. Applicant cites a portion of Bennet ¶[0045] where “the housing 102 may also comprise malleable materials, so that the housing may be shaped and bent to fit various configurations”, which would appear incompatible with increasing the strength of the housing (102) (specifically, the main body portion/”core” contained in the housing) such that the pores are configured to remain after the insulating film melts. While this argument has been fully considered, it has not been found persuasive; the teaching of one alternative with a housing comprising malleable materials being desirable for shaping and bending does not constitute a teaching away from any such alternative, i.e., a rigid housing. Bennet ¶[0044] discloses “the housing 102 may comprise a rigid structure, a semi-rigid structure, a membrane, or a bladder” (emphasis by Examiner), and ¶[0048] discussing the main body portion (112, “core”) only appears to envision the use of rigid materials. Thus, Bennet’s housing (102) which includes the main body portion (112) would not appear incompatible with increasing the strength (if not already present) such that the pores of the body portion are configured to remain after the insulating film melts to create a gas discharge passage as claimed. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to EVERETT T CHOI whose telephone number is (703)756-1331. The examiner can normally be reached Monday-Friday 11:00-8:00. 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, Jonathan G Leong can be reached on (571) 270 1292. 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. /E.C./Examiner, Art Unit 1751 /JONATHAN G LEONG/Supervisory Patent Examiner, Art Unit 1751 7/22/2026
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Prosecution Timeline

Show 3 earlier events
Aug 06, 2025
Response Filed
Sep 03, 2025
Final Rejection mailed — §103
Nov 03, 2025
Response after Non-Final Action
Dec 03, 2025
Request for Continued Examination
Dec 06, 2025
Response after Non-Final Action
Mar 12, 2026
Non-Final Rejection mailed — §103
Jun 11, 2026
Response Filed
Aug 05, 2026
Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12494537
BATTERY MODULE
3y 8m to grant Granted Dec 09, 2025
Patent 12381237
FUEL CELL STACK
3y 5m to grant Granted Aug 05, 2025
Study what changed to get past this examiner. Based on 2 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
12%
Grant Probability
-2%
With Interview (-14.3%)
3y 7m (~11m remaining)
Median Time to Grant
High
PTA Risk
Based on 17 resolved cases by this examiner. Grant probability derived from career allowance rate.

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