DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Election/Restrictions
Claims 16,17 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected Groups, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 07/24/2026.
Applicant’s election without traverse of Group I (Claims 1-15) in the reply filed on 07/24/2026 is acknowledged.
Claim Rejections - 35 USC § 102
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.
Claim(s) 1-4, 13,15 is/are rejected under 35 U.S.C. 102(a)(1) and 102(a)(2) as being anticipated by Park (US20130196194A1).
Regarding claim 1, Park discloses a battery cell (secondary battery 100; Fig 1, 2; [0053]), comprising:
a housing (battery case 110 [0056]);
a plurality of electrode assemblies (electrode assembly 10; [0054, 0059, 0063]), accommodated in the housing; and
a pressure relief mechanism (safety member 150; Fig 1; [0059-0060]), disposed on a first wall of the housing and located at a position on the first wall (“provided to at least one of the main body 111 and cover 112 of the battery; see Fig 1; [0059-0060]),
wherein the position is opposite to a middle region between two adjacent electrode assemblies among the plurality of electrode assemblies (i.e., the main body 111 and/or cover 112 comprising safety member 150 are parallel to, thus “is opposite to”, a middle region between two adjacent electrode assemblies; see Fig 1,2)
the pressure relief mechanism is configured to release an internal pressure of the battery cell when the internal pressure of the battery cell exceeds a threshold [0060].
Regarding claim 2, Park discloses the battery cell according to claim 1, wherein the battery cell is cuboidal (see Fig 1,2),
the pressure relief mechanism is located at a position on the first wall (i.e., on at least one of the main body 111 and cover 112 of the battery [0059-0060]), and
the position is opposite to a region between the two adjacent electrode assemblies arranged along a length direction of the battery cell (see Fig 2; [0059]).
Regarding claim 3, Park discloses the battery cell according to claim 2, wherein:
each of the electrode assemblies comprises a first electrode plate and a second electrode plate [0054], the first electrode plate and the second electrode plate are wound around a winding axis, the winding axis is parallel to the length direction of the battery cell (see annotated Fig 2 below; electrode plates winding around the “winding axis” that is parallel to the length direction of the battery cell, as annotated below).
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Regarding claim 4, Park discloses the battery cell according to claim 1, wherein two tabs of the electrode assembly are disposed on a first end face of the electrode assembly (first and second electrode tabs 120, 130; [0063]), the first end face is perpendicular to the length direction of the battery cell (i.e., a side in width direction; see Fig 1)
among the two adjacent electrode assemblies, a tab of one electrode assembly and a tab of the other electrode assembly are oriented in opposite directions and both oriented outward from the battery cell (i.e., tabs 120, 130 are on opposite ends of the electrode assembly 10 and are protruding outward from the secondary battery 100; see Fig 1, 2).
Regarding claim 13, Park discloses the battery cell according to claim 1, wherein the first wall is a bottom wall of the housing (i.e., the pressure relief mechanism is “provided to at least one of the main body 111 and cover 112 of the battery” which may be interpreted as “a bottom wall of the housing”; see Fig 1; [0059-0060]).
Regarding claim 15, Park discloses an electrical device (i.e., electronic devices such as a smart phone [Park 0050]), comprising a plurality of battery cells each being the battery cell according to claim 1, wherein the battery cells are configured to provide electrical energy [Park 0057].
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claim(s) 5-7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Park (US20130196194A1).
Regarding claim 5, Park discloses the battery cell according to claim 1. Park further discloses in another embodiment wherein the housing comprises a first opening (accommodating portion 311 a; see Fig 7) and a second opening (accommodating portion 311 b; Fig 7) opposite to each other along the length direction of the battery cell (the two accommodation portions 311a and 311b are on opposite ends in length direction of the secondary battery 300),
the battery cell further comprises a first end cap (i.e., upper portion of the cover 312 covering second electrode assemblies 10a; Fig 7) and a second end cap (i.e., lower portion of the cover 312 covering first electrode assemblies 10b; Fig 7), and the first end cap and the second end cap are configured to cover the first opening and the second opening respectively (i.e., accommodating portions 311a, 311b; see Fig 7). Park further discloses wherein such accommodation portions stably fixes the electrode assembly in the battery case without moving due to an external impact such as a vibration or drop, thereby preventing an electrical short circuit or the like [0074].
Thus, it would have been obvious for a person having ordinary skill in the art before the effective filing date to have modified the accommodation portion 111a of Fig 1 such that it includes two accommodation portions (i.e., the claimed first and second opening) with a reasonable expectation to stably fix the electrode assembly in the battery case and to further prevent an electrical short circuit [0074].
Regarding claim 6, Park discloses the battery cell according to claim 5, wherein:
the two adjacent electrode assemblies arranged along the length direction of the battery cell are insulated from each other (i.e., each electrode assembly is placed in its own accommodation portion 311a, 311b to avoid electrical short circuit [0074]).
Park further discloses wherein:
a first positive electrode terminal (e.g., 320d in Fig 7; 320d is considered to be a positive side based on [0063]) and a first negative electrode terminal (330d in Fig 7) of the battery cell are disposed on the first end cap (e.g., upper portion of the cover 312 covering second electrode assemblies 10a; Fig 7), and configured to lead out electrical energy of one of the two adjacent electrode assemblies (i.e., path of current (or electrons) generated in electrode assemblies [0063])
a second positive electrode terminal (e.g., 320b) and a second negative electrode terminal (e.g., 330b) of the battery cell are disposed on the second end cap (e.g., lower portion of the cover 312 covering second electrode assemblies 10b; Fig 7), and configured to lead out electrical energy of another one of the two adjacent electrode assemblies (i.e., path of current (or electrons) generated in electrode assemblies [0063])
Regarding claim 7, Park discloses the battery cell according to claim 1, wherein a thickness of the first wall is the thickness of the cover 112 or main body 111, but Park does not explicitly disclose wherein the thickness of the first wall is greater than a thickness of any other wall of the housing other than the first wall. Examiner notes that the change in size, without any new or unexpected results, is an obvious engineering design. See In re Rose, 220 F.2d 459, 105 USPQ 237 (see MPEP § 2144.04).
Claim(s) 8-11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Park (US20130196194A1), in view of Kaplan (US20090068548A1).
Regarding claim 8, Park discloses the battery cell according to claim 1, comprising the pressure relief mechanism to prevent explosion due to a sudden increase of the internal pressure [0060] but does not disclose wherein a thickness of the pressure relief mechanism at an effective position of the pressure relief mechanism is less than a thickness of the housing, and the effective position is a position to be burst open first on the pressure relief mechanism.
In this regard, Kaplan is directed to lithium ion prismatic cells comprising venting features in its cover (abstract), wherein the vent is a thin-walled area, wherein the wall thickness is selected to burst at high pressure before a dangerous condition is reached [0032 Kaplan]. As such, it would have been obvious for a person having ordinary skill in the art to have modified the thickness of the pressure relief mechanism such that it has a thickness less than the housing to avoid the cell from reaching a dangerous condition by allowing the vent to burst at high internal pressure [0032 Kaplan].
Regarding claim 9, Park discloses the battery cell according to claim 8, however, Park does not disclose the thickness of the pressure relief mechanism. In this regard, Kaplan teaches wherein the thickness of the vent in the cover is about 0.02-0.03 mm [0032 Kaplan], which falls within the claimed range of “greater than or equal to 0.01 mm and less than or equal to 0.5 mm”. it would have been obvious for a person having ordinary skill in the art to have selected the encompassing thickness range, with a reasonable expectation to rupture at high pressure before the cell reaches a dangerous condition [0032 Kaplan].
Regarding claim 10, Park discloses the battery cell according to claim 8. Park does not disclose “wherein a nick is created on the pressure relief mechanism, and the thickness of the pressure relief mechanism is a residual thickness of the nick”. In this regard, Kaplan teaches wherein the pressure relief mechanism (vent 107) has a nick (note: interpreted as a small cut, notch) wherein the thickness of the pressure relief mechanism comprising the nick is about 0.02-0.03mm [Kaplan 0032], wherein such nick is formed to propagate a crack [Kaplan 0032]. It would have been obvious for a person having ordinary skill in the art before the effective filing date to modified the pressure relief mechanism of Park such that it comprises a nick having such thickness with a reasonable expectation to propagate a crack when internal pressure continues to rise [Kaplan 0032].
Regarding claim 11, Park discloses the battery cell according to claim 1. Park does not disclose a thickness of the first wall, and further does not disclose “wherein a thickness of the first wall is greater than or equal to 0.2 mm and less than or equal to 3 mm” as claimed.
In this regard, Kaplan teaches wherein the thickness of the vent is about 0.02-0.03mm, wherein the wall thickness of the vent is typically about 6-10% of the wall thickness of the cover [Kaplan 0032]. Thus, the cover thickness is 0.3-0.333 mm, which falls within the claimed range of “greater than or equal to 0.2mm and less than or equal to 3mm”. It would have been obvious for a person having ordinary skill in the art before the effective filing date to have modified the thickness of the first wall, such that it is in the encompassing thickness range, with a reasonable expectation to rupture the vent instead of the cover at high internal pressure [0032 Kaplan].
Claim(s) 12,14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Park (US20130196194A1), in view of Zhao (WO2022006899A1, US equivalent US20220013855A1 was used as translation).
Regarding claim 12, Park discloses the battery cell according to claim 1 comprising a housing. However, Park does not disclose any thickness of the housing, and further does not disclose “wherein a thickness of any other wall of the housing other than the first wall is greater than or equal to 0.2 mm and less than or equal to 1 mm” as claimed.
In this regard, Zhao teaches a battery cell 20 comprising a plurality of electrode assemblies 22, a housing 211 with a pressure relief region 213 between the plurality of electrode assemblies (see Fig 3). Zhao further teaches wherein the side wall of the housing has a thickness of 1mm to 1.5mm [Zhao 0024], which overlaps with the claimed range of “greater than or equal to 0.2mm and less than or equal to 1mm”. It would have been obvious for a person having ordinary skill in the art before the effective filing date to have modified the walls of the housing other than the first wall (i.e., main body 111 in Fig 2 of Park) such that it is in the overlapping thickness range, with a reasonable expectation to form a housing capable of accommodating electrode assemblies.
Regarding claim 14, Park discloses the battery cell according to claim 1, wherein the battery cells are configured to provide electrical energy for an electronic device [0050]. However, Park does not disclose a battery comprising a plurality of the battery cells.
In this regard, Zhao teaches a battery 10 (e.g., battery module or pack; see Fig 1, 2; [0079-0083 Zhao]) comprising a plurality of battery cells (see Fig 3 of Zhao), wherein the battery cell comprises a plurality of electrode assembly 22 and a pressure relief mechanism 213 (Fig 4 of Zhao). Zhao further teaches such battery has large capacity and power [Zhao 0084]. Thus, it would have been obvious for a person having ordinary skill in the art before the effective filing date to have used a plurality of the battery cells according to claim 1 to form a battery, with a reasonable expectation to form an operation power source having large capacity and power [Zhao 0077-0084].
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to TAEYOUNG SON whose telephone number is (703)756-1427. The examiner can normally be reached M-F 8-5pm.
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/T.S./Examiner, Art Unit 1751
/JONATHAN G LEONG/Supervisory Patent Examiner, Art Unit 1751 8/9/2026
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