Prosecution Insights
Last updated: July 17, 2026
Application No. 18/547,205

APPARATUS FOR DISTRIBUTING ENERGY

Non-Final OA §103§112
Filed
Aug 21, 2023
Priority
Feb 22, 2021 — DE 10 2021 000 940.1 +1 more
Examiner
DJANAL-MANN, DOMINIQUE JOHANN
Art Unit
Tech Center
Assignee
Cellcentric GmbH & Co. Kg
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
15 currently pending
Career history
9
Total Applications
across all art units

Statute-Specific Performance

§103
100.0%
+60.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 0 resolved cases

Office Action

§103 §112
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after 2013 March 16, 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. DE10 2021 000 940.1, filed on 2021 February 22. Information Disclosure Statement The information disclosure statement (IDS) submitted on 2024 August 30 was filed after the mailing date of 2024 January 29. The submission is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. Specification The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed. The following title is suggested: A title that reflects the inventive concept of this particular Apparatus for Distributing Energy, that separates it from other apparatuses for distributing energy. 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 14 – 15 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. Claims 14 – 15 recite the limitation "the microcontroller". There is insufficient antecedent basis for this limitation in the claim — "the microcontroller" is never introduced within their dependency chains. The scope of those claims is therefore not reasonably certain. It is noted that both claims 3 and 5 (dependent upon claim 3) claim a/the microcontroller. 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 non-obviousness. Claim(s) 1, 3, 9 – 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), and further in view of SMITH et al. (US 2011/0217615 A1). In re claim 1, WALTER discloses a device for energy distribution in a fuel cell system (Fig. 1, circuit arrangement 10) having at least one fuel cell stack (fuel cell stack 11) and a high-voltage battery (¶[0025]: “… fuel cell systems are typically arranged between a high-voltage battery and a high-voltage intermediate circuit …”), having electrical terminals for the fuel cell stack (electrical connection point 15) and the high-voltage (HV) battery (electrical connection at output 16), and having at least one communication interface (low-voltage (LV) connection interface 28), having a converter (voltage converter 17), a battery circuit breaker for disconnecting the high-voltage battery and the fuel cell stack (interruption arrangement 21), and having an emergency shutdown device for connecting the poles of the fuel cell stack (¶[0026]: “Switch 20 is used to short-circuit the fuel cell stack 11 when needed.”), wherein the battery circuit breaker is arranged between the converter and the high-voltage battery (¶[0012], [0014]: interruption arrangement 21 arranged downstream of voltage converter 17 and upstream of output 16), and in that the battery circuit breaker is configured to disconnect both electrical poles of the connection (¶[0003], [0027]: first switch 22 in the positive-pole (outward) line and second switch 23 in the negative-pole (return) line, enabling bipolar disconnection of both electrical poles of the connection). WALTER is silent to wherein an EMC filter is provided. SMITH discloses that “typically, a DC-to-AC inverter is electrically connected to the DC bus for exporting electrical power from the fuel cell stack and preferably, an EMC filter (706) is electrically connected to the DC bus for reducing electromagnetic noise and transient voltages on the DC bus” (¶ [0031 and 0116]). It would have been obvious for a person having ordinary skill in the art (PHOSITA) to include an EMC filter in WALTER’s fuel cell connection box to reduce electromagnetic noise and transient voltages. In re claim 3, WALTER discloses wherein a microcontroller (microprocessor / microcontroller (μC) 24) is provided for controlling components (¶[0015], [0027]; μC 24 controls circuit state of switches 22, 23) and is connected to an external communication interface (¶[0028]: μC 24 connects to LV interface 28 via signal line 33). In re claims 9 – 10, WALTER discloses wherein main consumers are connected via battery terminals of the device (¶[0025]: output 16 connects to energy consumers), and a common housing is provided for mounting on the fuel cell stack (¶ [0007], [0012], [0014]: second module 14 mounted on fuel cell stack 11). Claim(s) 2, 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), and further in view of PARKS et al. (EP 2 901 467 B1). In re claim 2, WALTER discloses wherein the emergency shutdown device is connected to an external communication interface (¶[0028]: μC 24 connects to LV interface 28 via signal line 33). WALTER is silent to the emergency shutdown device comprises a pyrotechnic closer. PARKS discloses wherein the emergency shutdown device comprises a pyrotechnic closer (¶[0034] – [0035]: electrical pyrotechnic device 50 connects first and second conductive terminals 10, 20 via moveable body 30). It would have been obvious for a PHOSITA to implement WALTER's emergency shutdown switch as a pyrotechnic closer, providing irreversible pole-connection independent of control power, increasing safety reliability for the short-circuit emergency function. In re claim 11, WALTER discloses wherein a microcontroller (μC 24) is provided for controlling components (¶[0015], [0027]; μC 24 controls circuit state of switches 22, 23) and is connected to an external communication interface (¶[0028]: μC 24 connects to LV interface 28 via signal line 33). Claim(s) 4, 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), and further in view of BRENNER et al. (DE 10 2016 009 346 A1). In re claims 4, 13, WALTER is silent to wherein a device is provided for monitoring the insulation resistance, which is arranged in particular between the emergency shutdown device and the converter. BRENNER discloses wherein a device is provided for monitoring the insulation resistance (insulation monitor 14), which is arranged in particular between the emergency shutdown device and the converter (¶[0021] – [0022]: insulation monitor 14 connects to common electrical connection 16, between emergency shutdown side and the HV battery). It would have been obvious for a PHOSITA to include an insulation monitoring device in the WALTER’s fuel cell connection box for safe operation of HV fuel cell systems. Claim(s) 5 – 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), and further in view of ABOLHASSANI et al. (US 2010/0213921 A1). In re claims 5 – 6, WALTER discloses the converter is designed to be unidirectional (¶[0026]: voltage converter 17 incorporates diode 19). WALTER is silent to wherein a galvanically isolated adjustable transformer is provided, which is configured for high-voltage pre-charging and is connected to the low-voltage side of the converter and is controllable by the microcontroller. ABOLHASSANI discloses wherein a galvanically isolated adjustable transformer is provided (transformer 200, galvanic isolation between primary winding 210 and secondary windings 220), which is configured for high-voltage pre-charging (¶[0008], [0034]: auxiliary primary winding 230 charges DC-bus capacitors of power cells 620 to a predetermined high voltage threshold when active) and is connected to the low-voltage side of the converter (¶[0024]: auxiliary primary winding 230 is coupled to the LV auxiliary power source) and is controllable by the microcontroller (¶[0049]: master controller 640 controls the pre-charging sequence by monitoring DC bus voltage and commanding switching). It would have been obvious for a PHOSITA to provide a galvanically isolated adjustable transformer in WALTER’s fuel cell connection box to efficiently pre-charge high-voltage capacitive systems from a low-voltage source while limiting in-rush current. Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), and further in view of VARIGONDA et al. (US 2015/0229202 A1). In re claim 7, WALTER is silent to wherein a device for voltage limiting, in the case of an open circuit, is provided, which is arranged between the fuel cell stack and the converter and is controllable by the microcontroller. VARIGONDA discloses wherein a device for voltage limiting (auxiliary resistive load 29 and electronic switch 30), in the case of an open circuit, is provided, which is arranged between the fuel cell stack and the converter (FIG. 1 — auxiliary load 29, switch 30 on line 12 between fuel cell stack 13 and DC/DC converter 10) and is controllable by the microcontroller (VLD controller 34). It would have been obvious for a PHOSITA to provide a VLD in WALTER’s fuel cell connection box for protection of fuel cells from open-circuit voltage-induced corrosion. Claim(s) 8, 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), and further in view of SEDLACEK, JR. (US 2012/0028150 A1). In re claims 8, 19, WALTER is silent to wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system is provided between the EMC filter and the high-voltage battery. SMITH discloses an EMC filter is provided (EMC filter 706). A PHOSITA would be motivated to include an EMC filter in WALTER’s fuel cell connection box to reduce electromagnetic noise and transient voltages. SMITH is silent to wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system is provided between the EMC filter and the high-voltage battery. SEDLACEK discloses wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system (electrically conductive connections 52-58 including monitoring fuses 42-48, protecting fuel cells 30) is provided between the EMC filter and the high-voltage battery. It would have been obvious to incorporate fused electrical terminals for ancillary units into WALTER’s fuel cell connection box, and position them between the EMC filter output and the main HV battery connection terminal, to protect against fault currents and enable fault detection. Claim(s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), PARKS et al. (EP 2 901 467 B1), and further in view of BRENNER et al. (DE 10 2016 009 346 A1). In re claim 12, WALTER is silent to wherein a device is provided for monitoring the insulation resistance, which is arranged in particular between the emergency shutdown device and the converter. BRENNER discloses wherein a device is provided for monitoring the insulation resistance (insulation monitor 14), which is arranged in particular between the emergency shutdown device and the converter (¶[0021] – [0022]: insulation monitor 14 connects to common electrical connection 16, between emergency shutdown side and the HV battery). It would have been obvious for a PHOSITA to include an insulation monitoring device in the WALTER’s fuel cell connection box for safe operation of HV fuel cell systems. Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), BRENNER et al. (DE 10 2016 009 346 A1), and further in view of ABOLHASSANI et al. (US 2010/0213921 A1). In re claim 14, WALTER is silent to wherein a galvanically isolated adjustable transformer is provided, which is configured for high-voltage pre-charging and is connected to the low-voltage side of the converter and is controllable by the microcontroller. ABOLHASSANI discloses wherein a galvanically isolated adjustable transformer is provided (transformer 200, galvanic isolation between primary winding 210 and secondary windings 220), which is configured for high-voltage pre-charging (¶[0008], [0034]: auxiliary primary winding 230 charges DC-bus capacitors of power cells 620 to a predetermined high voltage threshold when active) and is connected to the low-voltage side of the converter (¶[0024]: auxiliary primary winding 230 is coupled to the LV auxiliary power source) and is controllable by the microcontroller (¶[0049]: master controller 640 controls the pre-charging sequence by monitoring DC bus voltage and commanding switching). It would have been obvious for a PHOSITA to provide a galvanically isolated adjustable transformer in WALTER’s fuel cell connection box to efficiently pre-charge high-voltage capacitive systems from a low-voltage source while limiting in-rush current. Claim(s) 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), BRENNER et al. (DE 10 2016 009 346 A1), and further in view of VARIGONDA et al. (US 2015/0229202 A1). In re claim 15, WALTER is silent to wherein a device for voltage limiting, in the case of an open circuit, is provided, which is arranged between the fuel cell stack and the converter and is controllable by the microcontroller. VARIGONDA discloses wherein a device for voltage limiting (auxiliary resistive load 29 and electronic switch 30), in the case of an open circuit, is provided, which is arranged between the fuel cell stack and the converter (FIG. 1 — auxiliary load 29, switch 30 on line 12 between fuel cell stack 13 and DC/DC converter 10) and is controllable by the microcontroller (VLD controller 34). It would have been obvious for a PHOSITA to provide a VLD in WALTER’s fuel cell connection box for protection of fuel cells from open-circuit voltage-induced corrosion. Claim(s) 16 – 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), ABOLHASSANI et al. (US 2010/0213921 A1), and further in view of VARIGONDA et al. (US 2015/0229202 A1). In re claims 16 – 17, WALTER is silent to wherein a device for voltage limiting, in the case of an open circuit, is provided, which is arranged between the fuel cell stack and the converter and is controllable by the microcontroller. VARIGONDA discloses wherein a device for voltage limiting (auxiliary resistive load 29 and electronic switch 30), in the case of an open circuit, is provided, which is arranged between the fuel cell stack and the converter (FIG. 1 — auxiliary load 29, switch 30 on line 12 between fuel cell stack 13 and DC/DC converter 10) and is controllable by the microcontroller (VLD controller 34). It would have been obvious for a PHOSITA to provide a VLD in WALTER’s fuel cell connection box for protection of fuel cells from open-circuit voltage-induced corrosion. Claim(s) 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), PARKS et al. (EP 2 901 467 B1), and further in view of SEDLACEK, JR. (US 2012/0028150 A1). In re claims 18, WALTER is silent to wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system is provided between the EMC filter and the high-voltage battery. SMITH discloses an EMC filter is provided (EMC filter 706). A PHOSITA would be motivated to include an EMC filter in WALTER’s fuel cell connection box to reduce electromagnetic noise and transient voltages. SMITH is silent to wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system is provided between the EMC filter and the high-voltage battery. SEDLACEK discloses wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system (electrically conductive connections 52-58 including monitoring fuses 42-48, protecting fuel cells 30) is provided between the EMC filter and the high-voltage battery. It would have been obvious to incorporate fused electrical terminals for ancillary units into WALTER’s fuel cell connection box, and position them between the EMC filter output and the main HV battery connection terminal, to protect against fault currents and enable fault detection. Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over WALTER (DE 10 2013 020 673 A1), SMITH et al. (US 2011/0217615 A1), BRENNER et al. (DE 10 2016 009 346 A1), and further in view of SEDLACEK, JR. (US 2012/0028150 A1). In re claims 20, WALTER is silent to wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system is provided between the EMC filter and the high-voltage battery. SMITH discloses an EMC filter is provided (EMC filter 706). A PHOSITA would be motivated to include an EMC filter in WALTER’s fuel cell connection box to reduce electromagnetic noise and transient voltages. SMITH is silent to wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system is provided between the EMC filter and the high-voltage battery. SEDLACEK discloses wherein at least one electrical terminal, protected by at least one fuse, for ancillary units of the fuel cell system (electrically conductive connections 52-58 including monitoring fuses 42-48, protecting fuel cells 30) is provided between the EMC filter and the high-voltage battery. It would have been obvious to incorporate fused electrical terminals for ancillary units into WALTER’s fuel cell connection box, and position them between the EMC filter output and the main HV battery connection terminal, to protect against fault currents and enable fault detection. Prior Art Disclaimer The prior art applied in this Office Action includes foreign patent documents that were originally published in languages other than English. Machine-generated translations of these documents were utilized to assess their relevance and content. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOHANN DJANAL-MANN whose telephone number is (571)272-4697. The examiner can normally be reached Monday - Friday 8:00 - 17:00. 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, Drew Dunn can be reached at (571) 272-2312. 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. /D. JOHANN DJANAL-MANN/ Examiner, Art Unit 2859 /DREW A DUNN/ Supervisory Patent Examiner, Art Unit 2859
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Prosecution Timeline

Aug 21, 2023
Application Filed
Jun 08, 2026
Non-Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
Grant Probability
Low
PTA Risk
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