Prosecution Insights
Last updated: October 02, 2026
Application No. 18/563,732

CHARGING CONTROL METHOD OF BATTERY PACK AND BATTERY SYSTEM USING THE SAME

Non-Final OA §101§102§103§112
Filed
Nov 22, 2023
Priority
Jan 06, 2022 — RE 10-2022-0002136 +1 more
Examiner
MCFARLAND, DANIEL PATRICK
Art Unit
Tech Center
Assignee
LG Energy Solution Ltd.
OA Round
1 (Non-Final)
28%
Grant Probability
At Risk
1-2
OA Rounds
10m
Est. Remaining
29%
With Interview

Examiner Intelligence

Grants only 28% of cases
28%
Career Allowance Rate
5 granted / 18 resolved
-32.2% vs TC avg
Minimal +1% lift
Without
With
+1.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
29 currently pending
Career history
54
Total Applications
across all art units

Statute-Specific Performance

§101
2.9%
-37.1% vs TC avg
§103
48.5%
+8.5% vs TC avg
§102
13.3%
-26.7% vs TC avg
§112
29.5%
-10.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 18 resolved cases

Office Action

§101 §102 §103 §112
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 Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statements (IDS) were submitted on 11/22/2023, 12/19/2024, and 02/20/2025. The submissions are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statements are being considered by the examiner. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the following must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. “plurality of battery packs” (claim 4) “generating a modulation charging rate” (claim 13) – Though Fig. 3 depicts a method in flowchart form, this claimed method step is not drawn. The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they include the following features not mentioned in the description: “Charging rate target SOC” (Figs. 2, 4) – This term is not used in the specification. It is suggested to revise this drawing label to be “Charging target SOC”. Corrected drawing sheets in compliance with 37 CFR 1.121(d) and/or amendment to the specification to add the reference character(s) in the description in compliance with 37 CFR 1.121(b) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Objections Claims 4 and 9-13 are objected to because of the following informalities: Claim 4 inconsistently uses the terms “temperature of the battery pack” (line 6) and “battery pack temperature” (line 7). The claim language should be revised for consistent terminology. Claims 9-13 use the terms “charging control method”, which is different than the “changing method” introduced in independent claim 8. The claim language should be revised for consistent terminology. Claim 13, line 5 uses the term “the method”, which is different than the “changing method” introduced in independent claim 8. The claim language should be revised for consistent terminology. Appropriate correction is required. 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 4, 9, and 13 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 4 is indefinite regarding the plurality of the “battery pack(s)” and the “charging target SOC(s)”. It is noted that similar claim 10 does not have these issues. Claim 1 introduced only a singular one of each of these features but claim 4 refers to these in the plural. Claim 4, line 6 also refers to only a singular “battery pack”. For examination purposes, it is interpreted there is only a singular “battery pack”. It is interpreted that the claim language “battery packs” is referring to a plurality of data points within the charging rate map. For examination purposes, it is interpreted that only a single “charging target SOC” is input to the battery management system. It is interpreted that the claim language “charging target SOCs” is referring to a plurality of data points within the charging rate map. Claim 9, line 6 recites “the PID value”. There is insufficient antecedent basis for this term in the claim language. Claim 13, line 2 recites “the battery system”. There is insufficient antecedent basis for this term in the claim language. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-13 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Examiner Note: The instant application discloses subject matter which may be used to overcome the 101 rejections by limiting the claimed invention to be more than an abstract idea if the subject matter is incorporated appropriately into the independent claims. The specification page 11, lines 19-21 recite “The BMS 20 transmits the compensation charging rate to the power converter 2. The power converter 2 may supply the power to the battery pack 10 according to the compensation charging rate.” Thus, it is suggested that claim 1 be amended to recite similar limitations to “transmit the compensation charging rate to a power converter, and wherein the power converter is configured to supply power to the battery pack according to the compensation charging rate”. Further, it is suggested that claim 8 be amended to recite similar limitations to “transmitting the compensation charging rate from the battery management system to a power converter, and supplying power to the battery pack from the power converter according to the compensation charging rate”. Step 1: Is the claim to a process, machine, manufacture, or composition of matter? Claims 1-7 recite “a battery system”. Thus, the claims are to a machine, which is one of the statutory categories of invention. Claims 8-13 recite “a charging method”. Thus, the claims are to a process, which is one of the statutory categories of invention. Step 2A Prong One: Does the claim recite an abstract idea? Independent Claim 1 recites: A battery system comprising: a battery pack including a plurality of battery cells; and a battery management system configured to: derive a charging rate based on a charging target state of charge (SOC) for the battery pack and a temperature of the battery pack [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations], compensate the charging rate through proportional-integral-derivative (PID) control based on an error voltage between any one of a plurality of cell voltages of the plurality of battery cells and an open circuit voltage (OCV) corresponding to the charging target SOC to generate a compensation charging rate [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Step 2A, Prong Two: Does the claim recite additional elements that integrate the abstract idea into a practical application? The elements that are not underlined above are the additional elements. The examiner finds that the additional elements “A battery system comprising: a battery pack including a plurality of battery cells; and a battery management system” do no more than generally link the use of the abstract idea to a particular technological environment or field of use because they are merely incidental or token additions to the claim that do not alter or affect how the apparatus’s configured capabilities to “derive a charging rate …” and “compensate the charging rate …” are performed. Thus, taken alone, the additional elements do not integrate the abstract idea into a practical application. Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. For example, there is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Step 2B: Does the claim recite additional elements that amount to significantly more than the abstract idea? The examiner finds that the additional elements do not amount to significantly more than the abstract idea for the same reasons discussed above with respect to the conclusion that the additional elements do not integrate the abstract idea into a practical application. Dependent Claim 2 recites: The battery system of claim 1, wherein the battery management system is configured to generate a proportional value, an integral value, and a differential value based on the error voltage to derive a PID value [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations], and multiply the charging rate by the PID value to generate the compensation charging rate [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 3 recites: The battery system of claim 2, wherein the battery management system is configured to derive the PID value by adding the proportional value, the integral value, and the differential value [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 4 recites: The battery system of claim 1, wherein the battery management system includes a charging rate map in which a charging rate corresponding to each temperature of a plurality of battery packs is defined for each of a plurality of charging target SOCs [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical relationships], and the battery management system is configured to receive the charging target SOCs and the temperature of the battery pack, and derive the charging rate corresponding to the received charging target SOCs and battery pack temperature from the charging rate map [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. The elements that are not underlined above are the additional elements. The examiner finds that the additional element “the battery management system is configured to receive the charging target SOCs and the temperature of the battery pack” does no more than generally link the use of the abstract idea to a particular technological environment or field of use. Dependent Claim 5 recites: The battery system of claim 1, wherein the battery management system is configured to generate the OCV corresponding to the charging target SOC by using an SOC to OCV conversion function [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 6 recites: The battery system of claim 1, wherein the battery management system is configured to generate the error voltage by subtracting a highest cell voltage among the plurality of cell voltages from the OCV [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 7 recites: The battery system of claim 1, wherein the battery system includes battery cell groups including battery cells among the plurality of battery cells connected in parallel, and the battery cell groups are connected to each other in series, and the battery management system is configured to generate a modulation charging rate by multiplying the compensation charging rate by the number of battery cell groups [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. The elements that are not underlined above are the additional elements. The examiner finds that the additional elements “wherein the battery system includes battery cell groups including battery cells among the plurality of battery cells connected in parallel, and the battery cell groups are connected to each other in series” does no more than generally link the use of the abstract idea to a particular technological environment or field of use. Independent Claim 8 recites: A charging method of a battery pack including a plurality of battery cells controlled by a battery management system, the charging method comprising: deriving a charging rate based on a charging target state of charge (SOC) for the battery pack and a temperature of the battery pack [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]; generating an error voltage between any one of a plurality of cell voltages and an open circuit voltage (OCV) corresponding to the charging target SOC [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]; and generating a compensation charging rate by compensating for the charging rate through proportional-integral-derivative (PID) control based on the error voltage [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Step 2A, Prong Two: Does the claim recite additional elements that integrate the abstract idea into a practical application? The elements that are not underlined above are the additional elements. The examiner finds that the additional elements “a battery pack including a plurality of battery cells controlled by a battery management system” do no more than generally link the use of the abstract idea to a particular technological environment or field of use because they are merely incidental or token additions to the claim that do not alter or affect how the process’s steps are performed. Thus, taken alone, the additional elements do not integrate the abstract idea into a practical application. Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. For example, there is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Step 2B: Does the claim recite additional elements that amount to significantly more than the abstract idea? The examiner finds that the additional elements do not amount to significantly more than the abstract idea for the same reasons discussed above with respect to the conclusion that the additional elements do not integrate the abstract idea into a practical application. Dependent Claim 9 recites: The charging control method of the battery pack of claim 8, wherein the generating of the compensation charging rate includes: generating a proportional value, an integral value, and a differential value based on the error voltage [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]; deriving the PID value by adding the proportional value, the integral value, and the differential value [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]; and multiplying the charging rate by the PID value to generate the compensation charging rate [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 10 recites: The charging control method of the battery pack of claim 8, wherein the deriving of the charging rate includes: receiving the charging target SOC and the battery pack temperature; and deriving the charging rate corresponding to the received charging target SOC and the temperature of the battery pack from a charging rate map [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. The elements that are not underlined above are the additional elements. The examiner finds the additional element “the deriving of the charging rate includes: receiving the charging target SOC and the battery pack temperature” does no more than generally link the use of the abstract idea to a particular technological environment or field of use. Dependent Claim 11 recites: The charging control method of the battery pack of claim 8, further comprising generating the OCV corresponding to the charging target SOC by using an SOC to OCV conversion function [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 12 recites: The charging control method of the battery pack of claim 8, wherein the generating of the error voltage includes: generating the error voltage by subtracting a highest cell voltage among the plurality of cell voltages from the OCV [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. Dependent Claim 13 recites: The charging control method of the battery pack of claim 8, wherein the battery system includes battery cell groups including battery cells among the plurality of battery cells connected in parallel, and the battery cell groups are connected to each other in series, and wherein the method further comprises: generating a modulation charging rate by multiplying the compensation charging rate by the number of battery cell groups [the examiner finds that the foregoing underlined elements recite mathematic concepts because they are mathematical calculations]. The elements that are not underlined above are the additional elements. The examiner finds the additional elements “wherein the battery system includes battery cell groups including battery cells among the plurality of battery cells connected in parallel, and the battery cell groups are connected to each other in series” do no more than generally link the use of the abstract idea to a particular technological environment or field of use. 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1 and 8 are rejected under 35 U.S.C. 102(a)(1)/102(a)(2) as being anticipated by Zhou et al. (US 2014/0214346 A1) and evidenced by Vuylsteke et al. (US 2022/0024438 A1; hereinafter “Vuy”). Regarding Claim 1, Zhou discloses a battery system (combo of the titular “high voltage lithium ion battery”, drawn as item “110”, and other features of “control system 100”; Fig. 1; referred to as a “battery system” in the Abstract) comprising the following features. PNG media_image1.png 797 1037 media_image1.png Greyscale Zhou further discloses a battery pack (¶ [2]: “High Voltage (HV) Lithium-Ion (Li-Ion) battery”; drawn as item “110” in Fig. 1; ¶ [21]: “internal combustion engine, battery or energy source 110”) including a plurality of battery cells (¶ [2]: “cells within a battery”; ¶ [2]: “comprised of cells”; thus, there are a plurality of battery cells within “110”). Zhou further discloses a battery management system (features of the “control system 100” other than “110”; Fig. 1) configured to perform the following actions. Zhou further discloses to derive a charging rate (“power limit from the feed forward calculation (power limit FFD) 272”; Fig. 2; ¶ [26]: “272 provides a first approximation of what the power limit of the system is capable of”; the power is for charging the battery pack per ¶ [2, 9]) based on a charging target state of charge (SOC) (Fig. 2 shows the target OCV “229” is input to “272”; it is widely understood that OCV and SOC are based on each other and translatable, as evidenced by Vuy’s Fig. 4, included infra; thus, because “272” is based on a target OCV, “272” is also based on a corresponding target SOC) for the battery pack (110) and a temperature (available power estimate is based on “cell temperature” per ¶ [5]) of the battery pack (110). PNG media_image2.png 904 1121 media_image2.png Greyscale Zhou further discloses to compensate the charging rate (272) through proportional-integral-derivative (PID) control (PID control is performed within “PID feedback compensator 222”; Fig. 2) based on an error voltage (“cell voltage error (CVE) 225”; Fig. 2; ¶ [27]: “CVE 225 is used as input to the PID feedback compensator 222”) between any one of a plurality of cell voltages (“actual cell voltage 224”; Fig. 2) of the plurality of battery cells (plurality of battery cells within “110” per ¶ [2, 21]) and an open circuit voltage (OCV) (“cell voltage target value 229”; Fig. 2) corresponding to the charging target SOC (it is widely understood that OCV and SOC are related and translatable, as evidenced by Vuy’s Fig. 4; thus, the target OCV “229” value must correspond to an SOC value) to generate a compensation charging rate (“power limit 230”; Fig. 2; ¶ [25]). PNG media_image3.png 866 1660 media_image3.png Greyscale Regarding Claim 8, Zhou discloses a charging method (Fig. 4; ¶ [34]: “method for estimating battery available power from a battery system in relation to a cell voltage”; per ¶ [9], also used for providing power to the battery pack for charging) of a battery pack (¶ [2]: “High Voltage (HV) Lithium-Ion (Li-Ion) battery”; drawn as item “110” in Fig. 1; ¶ [21]: “internal combustion engine, battery or energy source 110”) including a plurality of battery cells (¶ [2]: “cells within a battery”; ¶ [2]: “comprised of cells”; thus, there are a plurality of battery cells within “110”) controlled by a battery management system (features of the “control system 100” other than “110”; Fig. 1), the charging method comprising the following actions. Zhou further discloses deriving a charging rate (“power limit from the feed forward calculation (power limit FFD) 272”; Fig. 2; ¶ [26]: “272 provides a first approximation of what the power limit of the system is capable of”; the power is for charging the battery pack per ¶ [2, 9]) based on a charging target state of charge (SOC) (Fig. 2 shows the target OCV “229” is input to “272”; it is widely understood that OCV and SOC are based on each other and translatable, as evidenced by Vuy’s Fig. 4, included supra; thus, because “272” is based on a target OCV, “272” is also based on a corresponding target SOC) for the battery pack (110) and a temperature (available power estimate is based on “cell temperature” per ¶ [5]) of the battery pack (110). Zhou further discloses generating an error voltage (“cell voltage error (CVE) 225”; Fig. 2; ¶ [27]: “comparator 227 determines the difference between the two inputs and defines the difference at 225 to be the cell voltage error (CVE)”) between any one of a plurality of cell voltages (“actual cell voltage 224”; Fig. 2; plurality of battery cells within “110” per ¶ [2, 21]) and an open circuit voltage (OCV) (“cell voltage target value 229”; Fig. 2) corresponding to the charging target SOC (it is widely understood that OCV and SOC are related and translatable, as evidenced by Vuy’s Fig. 4; thus, the target OCV “229” value must correspond to an SOC value). Zhou further discloses generating a compensation charging rate (“power limit 230”; Fig. 2; ¶ [25]) by compensating for the charging rate (272) through proportional-integral-derivative (PID) control (PID control is performed within “PID feedback compensator 222”; Fig. 2) based on the error voltage (“CVE 225”; ¶ [27]: “CVE 225 is used as input to the PID feedback compensator 222”). 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. Claims 2-3 and 9 are rejected under 35 U.S.C. 103 as being unpatentable over Zhou et al. (US 2014/0214346 A1) in view of Nagato et al. (US 2020/0373836 A1) and Oyobe et al. (US 2010/0207587 A1). Regarding Claim 2, Zhou discloses the battery system of claim 1. Zhou further discloses the battery management system (100) is configured to derive a PID value (“Pwr limit FDBK 226”, output from “222” based on the error voltage “225”; Fig. 2). Zhou further discloses to add the charging rate (“Pwr limit FFD 272”) to the PID value (“Pwr limit FDBK 226”) to generate the compensation charging rate (“Pwr limit 230”, output from “228”; Fig. 2; ¶ [28]: “At 228, the comparator is additive of the inputs resulting in an output of a power limit 230 …. essentially a maximum power limitation of the capabilities”). Though Zhou discloses the battery management system is configured to derive a PID value, Zhou does not disclose “to generate a proportional value, an integral value, and a differential value based on the error voltage to derive a PID value”. Though Zhou discloses to add the charging rate to the PID value to generate the compensation charging rate, Zhou further does not disclose to “multiply the charging rate by the PID value to generate the compensation charging rate”. Nagato teaches to generate a proportional value (output from “proportional action unit 41”; Fig. 2; ¶ [42]: “41 outputs a product of a proportional gain Kp and voltage deviation U(n) as a proportional control variable”), an integral value (output from “integral action unit 42”; Fig. 2; ¶ [42]: “42 outputs a product of an integral value of voltage deviations U(1) to U(n) and an integral gain Ki as an integral control variable”), and a differential value (output from “derivative action unit 43”; Fig. 2; ¶ [42]: “43 outputs a product of a difference value between voltage deviations U(n) and U(n−1) and a derivative gain Kd as a derivative control variable”) based on the error voltage (“voltage deviation U(n)”; Fig. 1 shows “U(n)” is an error voltage, i.e. a difference between “target voltage Vf” and “output voltage Vout(n)”; Fig. 2 shows “U(n)” is input to each of “41-43”) to derive a PID value (“FB control variable Cfb(n)”, output from “adding unit 44”; Figs. 1-2). PNG media_image4.png 836 1437 media_image4.png Greyscale Nagato further teaches this control topology of generating proportional, integral, and differential values as being a widely known manner of implementing a PID compensator (Fig. 2), which enables the feedback compensation of an output voltage measurement based on a target voltage in a steady and controlled fashion (¶ [45]). 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 battery management system’s derivation of the PID value disclosed by Zhou to incorporate the generation of proportional, integral, and differential values based on the error voltage, as taught by Nagato, to implement the internal math within Zhou’s “PID Feedback Compensator 222”, which is not detailed within Zhou. Though the internal calculations within Zhou’s “PID Feedback Compensator 222” are not explicitly detailed by Zhou, it is clear from Nagato that PID calculations are well-established in the art. It would be obvious in view of Nagato to facilitate the feedback compensation of an output voltage measurement based on a target voltage in a steady and controlled fashion (Nagato ¶ [45]), thus resulting in a functional and practical implementation of Nagato’s control system. Oyobe teaches (annotated Fig. 5C included infra) to multiply the charging rate (“required power value Ps*”) by the PID value (“Pr1”, output from “PID control unit 85”) to generate the compensation charging rate (either/both of “target power values P1*, P2*”; ¶ [69, 84-85]; each value is generated from multiplying “Pr1” and “Ps*” via the “multiplying unit 86”). PNG media_image5.png 528 1703 media_image5.png Greyscale Oyobe further teaches to multiply the charging rate by the PID value to generate the compensation charging rate as a technique for adjusting the charging rate via a scaling/multiplying operation (Fig. 5C; ¶ [85]). NOTE 2-1: Zhou’s control system computes the compensated charging rate “230” by summing the charging rate “272” and the PID value “226”. In other words, Zhou’s control system uses the PID output as an offset to adjust the estimated charging rate. However, the prior art Oyobe demonstrates one may alternatively choose to design a PID compensation-based control system wherein a charging rate is multiplied by a PID value. In other words, the prior art demonstrates PID compensation may be designed either to variably offset (as in Zhou) or variably scale (as in Oyobe) a charging rate value (Zhou’s “272”; analogous to Oyobe’s “Ps*”). Each of these mathematical methods can be used to produce analogous results, wherein a charging rate is automatically and continuously adjusted by a PID value to produce a compensated charging rate. 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 battery management system disclosed by the combo of Zhou & Nagato to multiply the charging rate by the PID value to generate the compensation charging rate, as taught by Oyobe, as a method of scaling, instead of or in addition to offsetting, the charging rate. The multiplication method of Oyobe may result in a faster response to adjust the compensation charging rate than the summation choice of Zhou, thus improving the response time of the battery management system to respond to changes in cell voltages and/or temperatures. Regarding Claim 3, the combo of Zhou, Nagato, & Oyobe teaches the battery system of claim 2. The combo of Zhou, Nagato, & Oyobe teaches the battery management system (Zhou’s “100”, modified per teachings of Nagato & Oyobe) is configured to derive the PID value (Zhou: “226”; analogous to Nagato’s “Cfb(n)”; as detailed supra, Zhou’s “PID Feedback Compensator 222” can obviously be implemented as taught by Nagato’s Fig. 2, which details the calculations within a PID compensator) by adding (see annotated Nagato Fig. 2, included supra in the claim 2 section; Nagato’s “44” adds the outputs from “41-43”) the proportional value (Nagato: output from “proportional action unit 41”), the integral value (Nagato: output from “integral action unit 42”), and the differential value (Nagato: output from “derivative action unit 43”). Regarding Claim 9, Zhou discloses the charging control method of the battery pack of claim 8. Zhou further discloses the generating of the compensation charging rate (“Pwr limit 230”) includes deriving the PID value (“Pwr limit FDBK 226”, output from “222” based on the error voltage “225”; Fig. 2) based on the error voltage (225). Zhou further discloses adding the charging rate (“Pwr limit FFD 272”) to the PID value (“Pwr limit FDBK 226”) to generate the compensation charging rate (“Pwr limit 230”, output from “228”; Fig. 2; ¶ [28]: “At 228, the comparator is additive of the inputs resulting in an output of a power limit 230 …. essentially a maximum power limitation of the capabilities”). Though Zhou discloses the generating of the compensation charging rate includes deriving the PID value based on the error voltage, Zhou does not disclose “the generating of the compensation charging rate includes: generating a proportional value, an integral value, and a differential value based on the error voltage; deriving the PID value by adding the proportional value, the integral value, and the differential value”. Though Zhou discloses adding the charging rate to the PID value to generate the compensation charging rate, Zhou further does not disclose “multiplying the charging rate by the PID value to generate the compensation charging rate”. Nagato teaches generating a proportional value (output from “proportional action unit 41”; Fig. 2; ¶ [42]: “41 outputs a product of a proportional gain Kp and voltage deviation U(n) as a proportional control variable”), an integral value (output from “integral action unit 42”; Fig. 2; ¶ [42]: “42 outputs a product of an integral value of voltage deviations U(1) to U(n) and an integral gain Ki as an integral control variable”), and a differential value (output from “derivative action unit 43”; Fig. 2; ¶ [42]: “43 outputs a product of a difference value between voltage deviations U(n) and U(n−1) and a derivative gain Kd as a derivative control variable”) based on the error voltage (“voltage deviation U(n)”; Fig. 1 shows “U(n)” is an error voltage, i.e. a difference between “target voltage Vf” and “output voltage Vout(n)”; Fig. 2 shows “U(n)” is input to each of “41-43”). Nagato further teaches deriving the PID value (“FB control variable Cfb(n)”, output from “adding unit 44”; Figs. 1-2) by adding (“44” adds the outputs from “41-43”) the proportional value (output from “proportional action unit 41”), the integral value (output from “integral action unit 42”), and the differential value (output from “derivative action unit 43”). Nagato further teaches this control topology of generating proportional, integral, and differential values as being a widely known manner of implementing a PID compensator (Fig. 2), which enables the feedback compensation of an output voltage measurement based on a target voltage in a steady and controlled fashion (¶ [45]). 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 method’s derivation of the PID value disclosed by Zhou to incorporate the generation of proportional, integral, and differential values based on the error voltage, as taught by Nagato, to implement the internal math within Zhou’s “PID Feedback Compensator 222”, which is not detailed within Zhou. Though the internal calculations within Zhou’s “PID Feedback Compensator 222” are not explicitly detailed by Zhou, it is clear from Nagato that PID calculations are well-established in the art. It would be obvious in view of Nagato to facilitate the feedback compensation of an output voltage measurement based on a target voltage in a steady and controlled fashion (Nagato ¶ [45]), thus resulting in a functional and practical implementation of Nagato’s control system. Oyobe teaches (annotated Fig. 5C included supra in the claim 2 section) multiplying the charging rate (“required power value Ps*”) by the PID value (“Pr1”, output from “PID control unit 85”) to generate the compensation charging rate (either/both of “target power values P1*, P2*”; ¶ [69, 84-85]; each value is generated from multiplying “Pr1” and “Ps*” via the “multiplying unit 86”). Oyobe further teaches to multiply the charging rate by the PID value to generate the compensation charging rate as a technique for adjusting the charging rate via a scaling/multiplying operation (Fig. 5C; ¶ [85]). NOTE 9-1: Zhou’s control system computes the compensated charging rate “230” by summing the charging rate “272” and the PID value “226”. In other words, Zhou’s control system uses the PID output as an offset to adjust the estimated charging rate. However, the prior art Oyobe demonstrates one may alternatively choose to design a PID compensation-based control system wherein a charging rate is multiplied by a PID value. In other words, the prior art demonstrates PID compensation may be designed either to variably offset (as in Zhou) or variably scale (as in Oyobe) a charging rate value (Zhou’s “272”; analogous to Oyobe’s “Ps*”). Each of these mathematical methods can be used to produce analogous results, wherein a charging rate is automatically and continuously adjusted by a PID value to produce a compensated charging rate. 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 method disclosed by the combo of Zhou & Nagato to multiply the charging rate by the PID value to generate the compensation charging rate, as taught by Oyobe, as a method of scaling, instead of or in addition to offsetting, the charging rate. The multiplication method of Oyobe may result in a faster response to adjust the compensation charging rate than the summation choice of Zhou, thus improving the response time of the battery management system to respond to changes in cell voltages and/or temperatures. Claims 4 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over Zhou et al. (US 2014/0214346 A1) in view of Lee et al. (US 2020/0287390 A1). Regarding Claim 4, Zhou discloses the battery system of claim 1. As addressed supra, Zhou discloses the battery management system is configured to derive a charging rate based on a charging target SOC for the battery pack and a temperature of the battery pack. However, Zhou does not disclose “the battery management system includes a charging rate map in which a charging rate corresponding to each temperature of a plurality of battery packs is defined for each of a plurality of charging target SOCs, and the battery management system is configured to receive the charging target SOCs and the temperature of the battery pack, and derive the charging rate corresponding to the received charging target SOCs and battery pack temperature from the charging rate map”. Lee teaches (see annotated Fig. 4 infra) the battery management system (combo of “DC converter 11”, “controller 14”, and “intelligent battery sensor (IBS) 15”; Fig. 1) includes a charging rate map (“data map 141”; Fig. 4) in which a charging rate (“maximum charging current”; Fig. 4; ¶ [54]: “14 … inputs the temperature and the charge state into the data map 141 and then derives the maximum charging current corresponding thereto at step S131”) corresponding to each temperature (data within “141” associated with “auxiliary battery temperature” input; Fig. 4) of a plurality of battery packs (in view of the instant app’s disclosure, it is interpreted that “packs” in plural is referring to a plurality of 2-dimensional data points within the charging rate map) is defined for each of a plurality of charging target SOCs (data within “141” associated with “auxiliary battery SOC” input; Fig.). PNG media_image6.png 550 1143 media_image6.png Greyscale Lee further teaches the battery management system (11, 14, 15) is configured to receive the charging target SOCs (“auxiliary battery SOC”; Fig. 4) and the temperature of the battery pack (“auxiliary battery temperature”; Fig. 4). Lee further teaches to derive the charging rate (“maximum charging current”; Fig. 4) corresponding to the received charging target SOCs (“auxiliary battery SOC”) and battery pack temperature (“auxiliary battery temperature”) from the charging rate map (141). Lee further teaches the charging rate map to improve the charging efficiency of the battery pack (¶ [8]). 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 battery management system disclosed by Zhou to incorporate a charging rate map, as taught by Lee, to improve the efficiency of charging the battery pack. Regarding Claim 10, Zhou discloses the charging control method of the battery pack of claim 8. As addressed supra, Zhou discloses deriving a charging rate based on a charging target SOC for the battery pack and a temperature of the battery pack. However, Zhou does not disclose “the deriving of the charging rate includes: receiving the charging target SOC and the battery pack temperature; and deriving the charging rate corresponding to the received charging target SOC and the temperature of the battery pack from a charging rate map”. Lee teaches (see annotated Fig. 4 supra in the claim 4 section) the deriving of the charging rate (“maximum charging current”; Fig. 4; ¶ [54]: “14 … inputs the temperature and the charge state into the data map 141 and then derives the maximum charging current corresponding thereto at step S131”) includes: receiving the charging target SOC (“auxiliary battery SOC”; Fig. 4) and the battery pack temperature (“auxiliary battery temperature”; Fig. 4); and deriving the charging rate corresponding to the received charging target SOC and the temperature of the battery pack from a charging rate map (“data map 141”; Fig. 4). Lee further teaches the charging rate map to improve the charging efficiency of the battery pack (¶ [8]). 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 method’s derivation of the charging rate disclosed by Zhou to use a charging rate map, as taught by Lee, to improve the efficiency of charging the battery pack. Claims 5 and 11 are rejected under 35 U.S.C. 103 as being unpatentable over Zhou et al. (US 2014/0214346 A1) in view of Borhan et al. (US 2015/0326037 A1) and Seeman et al. (US 2020/0223322 A1). Regarding Claim 5, Zhou discloses the battery system of claim 1. Zhou does not disclose “the battery management system is configured to generate the OCV corresponding to the charging target SOC by using an SOC to OCV conversion function”. Borhan teaches the battery management system (“140”; Fig. 1) is configured to consider the charging target SOC (Fig. 5, step 502: “Determine target SOC”; ¶ [25]: “target SOC refers to the level of charge that the battery will be (is intended to be) charged to”) as an input to determine the charging technique (Fig. 5, step 505: “Select charging solution”). Borhan provides motivation for a target SOC to be an input to the battery management system because it enables the target charge level to be set based on the desire of a user (¶ [25]), thus improving flexibility and convenience for the user. Seeman teaches the battery management system (“controller 50”; Fig. 1) is configured to generate the OCV (“OCV”, output from “108”; Fig. 6A) corresponding to the SOC input (“106”, input to “108”) by using an SOC to OCV conversion function (“108”; Fig. 6A; ¶ [40]: “Within the logic block 108, the controller 50 accesses an SOC-to-OCV lookup table stored in memory (M), with state of charge (SOC) and open-circuit voltage (OCV) described above. The pack-level OCV is extracted from the lookup table and fed into an operating block 110.”). Seeman further teaches the SOC to OCV conversion function enables the conversion of an SOC input to an OCV value which is usable for a voltage-based control process (Fig. 6A). 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 battery management system disclosed by Zhou to enable the input of a user-set charging target SOC, as taught by Borhan, by incorporating an SOC to OCV conversion function, as taught by Seeman, to improve flexibility and convenience for the user. Regarding Claim 11, Zhou discloses the charging control method of the battery pack of claim 8. Zhou does not disclose “generating the OCV corresponding to the charging target SOC by using an SOC to OCV conversion function”. Borhan teaches to consider the charging target SOC (Fig. 5, step 502: “Determine target SOC”; ¶ [25]: “target SOC refers to the level of charge that the battery will be (is intended to be) charged to”) as an input to determine the charging technique (Fig. 5, step 505: “Select charging solution”). Borhan provides motivation for a target SOC to be an input because it enables the target charge level to be set based on the desire of a user (¶ [25]), thus improving flexibility and convenience for the user. Seeman teaches generating the OCV (“OCV”, output from “108”; Fig. 6A) corresponding to the SOC input (“106”, input to “108”) by using an SOC to OCV conversion function (“108”; Fig. 6A; ¶ [40]: “Within the logic block 108, the controller 50 accesses an SOC-to-OCV lookup table stored in memory (M), with state of charge (SOC) and open-circuit voltage (OCV) described above. The pack-level OCV is extracted from the lookup table and fed into an operating block 110.”). Seeman further teaches the SOC to OCV conversion function enables the conversion of an SOC input to an OCV value which is usable for a voltage-based control process (Fig. 6A). 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 method disclosed by Zhou to enable the input of a user-set charging target SOC, as taught by Borhan, by incorporating an SOC to OCV conversion function, as taught by Seeman, to improve flexibility and convenience for the user. Claims 6 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Zhou et al. (US 2014/0214346 A1) in view of Kawachi et al. (WO 2016/147326 A1). Regarding Claim 6, Zhou discloses the battery system of claim 1. Zhou further discloses the battery management system (“100”, except “110”) is configured to generate the error voltage (“cell voltage error (CVE) 225”) by subtracting a cell voltage (“actual cell voltage 224”) among the plurality of cell voltages (plurality of battery cells within “110” per ¶ [2, 21]) from the OCV (“cell voltage target value 229”). Zhou does not disclose the considered cell voltage is “a highest cell voltage”. Kawachi teaches the battery management system (title: “storage-battery management device”) is configured to generate the error voltage (step S13 of Figs. 5-6; pp. 4, 6th para.: “differential voltage ΔV during charging is calculated by subtracting the maximum cell voltage from the upper limit of the cell voltage”) by subtracting a highest cell voltage (“maximum cell voltage”) among the plurality of cell voltages (pp. 4, 5th para.: “voltage limit calculation unit 92 calculates the maximum cell voltage … from among the cell voltages of each battery cell 61-1 to 61-10 detected by the cell voltage detection unit 91”, detected in step S12) from the OCV (“upper limit of the cell voltage”). Kawachi further teaches to choose the highest cell voltage for the error voltage calculation ensures safety and suppresses degradation of the battery cells by preventing overvoltage damage (pp. 2 Description, 2nd & 5th paras.). 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 battery management system disclosed by Zhou to choose the highest cell voltage for the error voltage calculation, as taught by Kawachi, to improve safety and suppress degradation by preventing overvoltage damage. Regarding Claim 12, Zhou discloses the charging control method of the battery pack of claim 8. Zhou further discloses the generating of the error voltage (“cell voltage error (CVE) 225”) includes: generating the error voltage by subtracting a cell voltage (“actual cell voltage 224”) among the plurality of cell voltages (plurality of battery cells within “110” per ¶ [2, 21]) from the OCV (“cell voltage target value 229”). Zhou does not disclose the considered cell voltage is “a highest cell voltage”. Kawachi teaches the generating of the error voltage (step S13 of Figs. 5-6; pp. 4, 6th para.: “differential voltage ΔV during charging is calculated by subtracting the maximum cell voltage from the upper limit of the cell voltage”) includes: generating the error voltage (ΔV) by subtracting a highest cell voltage (“maximum cell voltage”) among the plurality of cell voltages (pp. 4, 5th para.: “voltage limit calculation unit 92 calculates the maximum cell voltage … from among the cell voltages of each battery cell 61-1 to 61-10 detected by the cell voltage detection unit 91”, detected in step S12) from the OCV (“upper limit of the cell voltage”). Kawachi further teaches to choose the highest cell voltage for the error voltage calculation ensures safety and suppresses degradation of the battery cells by preventing overvoltage damage (pp. 2 Description, 2nd & 5th paras.). 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 method disclosed by Zhou to choose the highest cell voltage for the error voltage calculation, as taught by Kawachi, to improve safety and suppress degradation by preventing overvoltage damage. Claims 7 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Zhou et al. (US 2014/0214346 A1) in view of Sugeno (US 2018/0198289 A1). Regarding Claim 7, Zhou discloses the battery system of claim 1. Zhou does not disclose “the battery system includes battery cell groups including battery cells among the plurality of battery cells connected in parallel, and the battery cell groups are connected to each other in series, and the battery management system is configured to generate a modulation charging rate by multiplying the compensation charging rate by the number of battery cell groups”. Sugeno teaches the battery system (Fig. 7, including the battery pack configuration of Fig. 4) includes battery cell groups (¶ [3]: “a battery pack which is configured by serial connection of secondary batteries (appropriately referred to as battery cells) or sub modules (sometimes, referred to as battery blocks) configured by parallel connection of a plurality of battery cells”; Fig. 4) including battery cells among the plurality of battery cells connected in parallel (Fig. 4 shows each “sub module” including two cells connected in parallel). Sugeno further teaches the battery cell groups are connected to each other in series (¶ [59]: “parallel connections (sub modules) of a plurality of the cells are connected in series”). PNG media_image7.png 889 1551 media_image7.png Greyscale Sugeno further teaches (see “equation (1)”; ¶ [9-10]) the battery management system is configured to generate a modulation charging voltage (“Maximum Charging Voltage”) by multiplying the compensation charging voltage (difference of “Fully Charged Voltage – Maximum Cell Voltage”) by the number of battery cell groups (“n”; ¶ [10]: “n represents a total number of the battery cells connected in series”). NOTE 7-1: Sugeno teaches the modulation of charging voltages, rather than charging rates. However, it was already set forth by the primary reference Zhou to control charging rates, i.e., charging power. It is well known in the art that power is directly proportional to voltage. By modulating the charging voltage to adjust for the number of cell groups, as taught by Sugeno, one would also be modulating the charging rates. Thus, Sugeno’s modulation of charging voltage is analogous to modulation of Zhou’s charging rate/power. Sugeno further teaches the modulation of the charging rate to more quickly charge a high voltage, high capacity battery pack, such as is needed for an electric vehicle (¶ [3, 8, 19]) 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 battery system disclosed by Zhou to incorporate a plurality of battery cell groups in the battery pack, for which a modulation charging rate is generated by multiplying the compensation charging rate by the number of series groups, based on the teachings of Sugeno, to use a higher voltage, higher capacity battery pack and to shorten the charging time associated with said battery pack. Thus, the combo of Zhou & Sugeno teaches the battery management system is configured to generate a modulation charging rate by multiplying the compensation charging rate by the number of battery cell groups. Regarding Claim 13, Zhou discloses the charging control method of the battery pack of claim 8. Zhou does not disclose “the battery system includes battery cell groups including battery cells among the plurality of battery cells connected in parallel, and the battery cell groups are connected to each other in series, and wherein the method further comprises: generating a modulation charging rate by multiplying the compensation charging rate by the number of battery cell groups”. Sugeno teaches the battery system (Fig. 7, including the battery pack configuration of Fig. 4) includes battery cell groups (¶ [3]: “a battery pack which is configured by serial connection of secondary batteries (appropriately referred to as battery cells) or sub modules (sometimes, referred to as battery blocks) configured by parallel connection of a plurality of battery cells”; Fig. 4) including battery cells among the plurality of battery cells connected in parallel (Fig. 4 shows each “sub module” including two cells connected in parallel). Sugeno further teaches the battery cell groups are connected to each other in series (¶ [59]: “parallel connections (sub modules) of a plurality of the cells are connected in series”). Sugeno further teaches (see “equation (1)”; ¶ [9-10]) the method further comprises: generating a modulation charging voltage (“Maximum Charging Voltage”; see note 7-1, included supra) by multiplying the compensation charging voltage (difference of “Fully Charged Voltage – Maximum Cell Voltage”; see note 7-1, included supra) by the number of battery cell groups (“n”; ¶ [10]: “n represents a total number of the battery cells connected in series”). Sugeno further teaches the modulation of the charging rate to more quickly charge a high voltage, high capacity battery pack, such as is needed for an electric vehicle (¶ [3, 8, 19]) 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 battery system and method disclosed by Zhou to incorporate a plurality of battery cell groups in the battery pack, for which a modulation charging rate is generated by multiplying the compensation charging rate by the number of series groups, based on the teachings of Sugeno, to use a higher voltage, higher capacity battery pack and to shorten the charging time associated with said battery pack. Thus, the combo of Zhou & Sugeno teaches the method further comprises: generating a modulation charging rate by multiplying the compensation charging rate by the number of battery cell groups. Conclusion The following prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Bryan et al. (US 2022/0258609 A1) PNG media_image8.png 898 575 media_image8.png Greyscale Duan et al. (US 2020/0055405 A1) PNG media_image9.png 420 562 media_image9.png Greyscale Robotham (US 2019/0199102 A1) PNG media_image10.png 758 388 media_image10.png Greyscale PNG media_image11.png 892 457 media_image11.png Greyscale Hand, III et al. (US 2018/0050603 A1) PNG media_image12.png 446 631 media_image12.png Greyscale Tashiro (US 2013/0043844 A1) PNG media_image13.png 851 474 media_image13.png Greyscale Heap et al. (US 2009/0118080 A1) PNG media_image14.png 862 453 media_image14.png Greyscale McGee et al. (US 2006/0022642 A1) PNG media_image15.png 906 311 media_image15.png Greyscale Any inquiry concerning this communication or earlier communications from the examiner should be directed to Daniel P McFarland whose telephone number is (571)272-5952. The examiner can normally be reached Monday-Friday, 7:30 AM - 4:00 PM Eastern. 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. /DANIEL P MCFARLAND/ Examiner, Art Unit 2859 /DREW A DUNN/ Supervisory Patent Examiner, Art Unit 2859
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Prosecution Timeline

Nov 22, 2023
Application Filed
Sep 16, 2026
Non-Final Rejection mailed — §101, §102, §103 (current)

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