Prosecution Insights
Last updated: October 04, 2026
Application No. 18/623,274

STORAGE SYSTEM CONFIGURED FOR USE WITH AN ENERGY MANAGEMENT SYSTEM

Non-Final OA §101§103
Filed
Apr 01, 2024
Priority
Apr 05, 2023 — provisional 63/457,197
Examiner
GEISS, BRIAN BUTLER
Art Unit
Tech Center
Assignee
Enphase Energy Inc.
OA Round
1 (Non-Final)
70%
Grant Probability
Favorable
1-2
OA Rounds
8m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allowance Rate
48 granted / 69 resolved
+9.6% vs TC avg
Strong +26% interview lift
Without
With
+26.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
17 currently pending
Career history
91
Total Applications
across all art units

Statute-Specific Performance

§101
25.0%
-15.0% vs TC avg
§103
48.3%
+8.3% vs TC avg
§102
16.1%
-23.9% vs TC avg
§112
9.4%
-30.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 69 resolved cases

Office Action

§101 §103
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 . 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 1-19 are rejected under 35 U.S.C. 101 because the claimed invention in each of these claims is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Specifically, representative Claim 8 recites: “A method for managing a storage system configured for use with an energy management system, comprising: receiving a local coulomb count from each microinverter of a plurality of microinverters of a power converter; calculating a total battery coulomb count; obtaining a voltage measurement of a battery; and calculating a state-of-charge estimate using a calculated total battery coulomb count and an obtained voltage measurement.” The claim limitations considered to fall within in the abstract idea are highlighted in bold font above; the remaining features are “additional elements.” Step 1 of the subject matter eligibility analysis entails determining whether the claimed subject matter falls within one of the four statutory categories of patentable subject matter identified by 35 U.S.C. 101: process, machine, manufacture, or composition of matter. Claim 1 recites a process and is therefore falls within a statutory category. Step 2A, Prong One of the analysis entails determining whether the claim recites a judicial exception such as an abstract idea. Under a broadest reasonable interpretation, the highlighted portion of claim 1 comprises process steps that fall within the abstract idea judicial exception. Specifically, under the 2019 Revised Patent Subject matter Eligibility Guidance, the highlighted subject matter falls within the mental processes category. Individually and collectively, the steps: “receiving a local coulomb count from each microinverter of a plurality of microinverters of a power converter”; “calculating a total battery coulomb count”; “obtaining a voltage measurement of a battery”; and “calculating a state-of-charge estimate using a calculated total battery coulomb count and an obtained voltage measurement” may be performed as mental processes and/or are mathematical calculations. Receiving a local coulomb count and obtaining a voltage measurement are each collecting information, which may be performed as mental processes. Calculating a total battery coulomb count and calculating a state-of-charge estimate are calculations, which may be performed as mathematical calculations and/or analysis which may be performed as mental processes. The type of high-level information collecting and analyzing data recited in these elements has been found by the Federal Circuit to constitute patent ineligible matter (see Electric Power Group v. Alstom, S.A., 830 F.3d 1350, 1353-54, 119 USPQ2d 1739, 1741-42 (Fed. Cir. 2016), a claim to "collecting information, analyzing it, and displaying certain results of the collection and analysis," where the data analysis steps are recited at a high level of generality such that they could practically be performed in the human mind). Similar limitations comprise the mental processes type abstract idea recited by independent claims 1 and 14. Step 2A, Prong Two of the analysis entails determining whether a claim includes additional elements that integrate the recited judicial exception (e.g., abstract idea) into a practical application. In view of the various considerations encompassed by the Step 2A, Prong Two analysis, claim 1 does not include additional elements that integrate the recited abstract idea into a practical application. Based on the individual and collective limitations of claim 1, applying a broadest reasonable interpretation, the most significant of such considerations appear to include: improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)); applying the judicial exception with, or by use of, a particular machine (MPEP 2106.05(b)); and effecting a transformation or reduction of a particular article to a different state or thing (MPEP 2106.05(c)). Regarding improvements to the functioning of a computer or other technology, none of the “additional elements” in any combination appear to integrate the abstract idea to technologically improve any aspect of a system that may be used to implement the highlighted steps such a generic computer. Any alleged improvement would be an improvement is the process steps, thus an improvement in the abstract ideas, therefore not an improvement in technology (MPEP 2106.05(a).II “However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology.”.). Regarding application of the judicial exception with, or by use of, a particular machine, the additional elements such as the “storage system configured for use with an energy management system” are not utilized as a particularized manner of implementing the abstract idea process steps. Regarding effectuation of a transformation or reduction of a particular article to a different state or thing, the claim includes no such transformation or reduction. Instead, the claim as a whole entails gathering information and performing analysis and/or mathematical calculations on said information. Independent claim 1 recites additional elements including “a battery”, “a power converter”, and “a battery management unit” amounts to merely the object on which the method operates (MPEP 2106.05(b).II), and is not a particular machine, and therefore does not integrate the judicial exception. Independent claim 14 recites additional elements including “a non-transitory computer readable storage medium having stored thereon instructions that when executed by a processor”, which amounts to mere instruction to implement the process steps on a generic computer (MPEP 2106.05(f)), which does not integrate the judicial exception into a practical application. The above additional elements, considered individually and in combination with the claim elements reciting an abstract idea do not reflect an improvement to other technology or technical field, and, therefore, do not integrate the judicial exception into a practical application. Therefore, the claims are directed to a judicial exception and require further analysis under Step 2B. Regarding Step 2B, independent claims 1, 8 and 14, do not include additional elements that are sufficient to amount to significantly more than the judicial exception because they are generically recited and are well-understood/conventional in the relevant art as evidenced by the prior art of record as indicated in the rejections under 35 U.S.C. §103. Independent claims 1, 8 and 14 are therefore not patent eligible. Dependent claims 2-7, 9-13 and 15-19 provide additional features/steps which are part of an expanded process that includes the abstract idea of the independent claims (Step 2A, Prong One). None of dependent claims 2-18 and 20 recite additional elements that integrate the abstract idea into practical application (Step 2A, Prong Two). Claims 2, 5, 9, 12, 15 and 18 further detail the frequency of received local coulomb counts. Claims 3, 10, and 16 further details the calculation of the state-of-charge. Claims 4, 11, and 17 further details the number of microinverters. Claims 6 further details the voltage measurement. Claims 7, 13, and 19 further details the power converter. Claims 2-7, 9-13 and 15-19 all fail the “significantly more” test under the step 2B for the same reasons as discussed with regards to the independent claims. The dependent claims 2-7, 9-13 and 15-19 therefore are also ineligible subject matter. 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. Claim(s) 1-19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sharma et al. (US 20220302724 A1) in view of Gullu et al. (S. Gullu, J. Phelps, I. Batarseh, K. Alluhaybi, M. Salameh and S. Al-Hallaj, "Smart Battery Management System for Integrated PV, Microinverter and Energy Storage," 2021 12th International Renewable Energy Congress (IREC), Hammamet, Tunisia, 2021, pp. 1-6, doi: 10.1109/IREC52758.2021.9624748.) and Smedley et al. (US 20150002099 A1). Regarding claim 1, Sharma teaches A storage system (Abstract; Fig. 1, system 100) configured for use with an energy management system ([0051] lines 10-13, “System 100 can be used for discharging power from battery packs 20 to a grid 85, or for charging from the grid 85 to battery packs 20.”), comprising: a battery (battery 20; Fig. 3; [0057] lines 6-7, “The battery set 27 may include one or more batteries 21”); a power converter (power converter 10) comprising a plurality of (Fig. 1, inverter 40); and a battery management unit coupled to the battery and the power converter (Fig. 1, battery power management unit (BPMU) 30) and configured to receive a local coulomb count from each ([0066] lines 1-5, “In some embodiments, each BPMU 30 is also configured to determine state of health (SOH) of each respective battery pack 20 based on the capacity of the respective battery pack 20. A suitable technique including, but not limited to, Coulomb counting”) , obtain a voltage measurement of the battery (Fig. 7, step 206), and calculate a state-of-charge estimate using a calculated ([0081] At step 210, state of charge (SOC) of the respective battery pack 20 is determined and updated based on the initial value of SOC, the current, and the time interval. In some embodiments, a suitable technique such as Coulomb counting, electrochemical impedance measurement, or any other suitable techniques, or a combination thereof is used for determining the SOH and the SOC of each respective battery pack.). The SOC is the state-of-charge estimate. Sharma does not teach the system, comprising: microinverter coupled to the battery; calculate a total battery coulomb count, and calculate a state-of-charge estimate using a calculated total battery coulomb count. Gullu teaches an analogous system (Abstract), comprising: a microinverter coupled to the battery (Figs. 1 and 5; p. 2 “3-port micro inverter is used. One port is connected to the PV panel as an input, one port that is bidirectional is connected to the battery pack, and another port is connected to the load.”). It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Sharma to substitute the inverters for microinverters because the use of microinverters as inverters is well known in the art and yields predictable results, such as reducing the size of the components. Sharma in view of Gullu does not teach the system, comprising: calculate a total battery coulomb count, and calculate a state-of-charge estimate using a calculated total battery coulomb count Smedley teaches an analogous system (Abstract), comprising: calculate a total battery coulomb count ([0044] lines 1-4, “At reference numeral 708, the process 700 includes the BMC controller 120 calculating a sum S of the battery status signals Bsi. For example, the sum may be determined according to S=.SIGMA..sub.i=1.sup.nBsi.”; [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”), and calculate a state-of-charge estimate using a calculated total battery coulomb count ([0026] lines 1-9, “state of charge SOCi may be defined as available charge in a battery cell, expressed as a percentage of present capacity. To estimate the SOCi, a coulomb counting method, based on counting the amount of charge being given to or taken from a cell over change in time, for example, may be relied upon. Cumulative error of estimated SOCi may be corrected using a lookup table LTi representative of a function of the battery terminal voltage Vbi and temperature Ti at a rest state whenever possible.”; [0031] lines 1-4, “Based on the battery status parameters, each of the BCC controllers 1-n 110 generates a corresponding battery status signal Bsi according to, for example, equation (6) below. Bsi = f ( SOCi - .chi. ) Q i Vbi , where .chi. = { 1 charging 0 discharging”; [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”). It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Sharma in view of Gullu to include the total battery coulomb count of Smedley because the calculation of a total coulomb count of a battery would yield predictable results, such as determining the total coulomb count across the respective battery cells. Regarding claim 2, Sharma in view of Gullu and Smedley teaches The storage system of claim 1, wherein the battery management unit is configured to receive the local coulomb count from each microinverter at about 0.1 to 10 Hz or times per second (Sharma: [0071] lines 6-8, “The BPMU 30 provides real time and reliable data for the system controller 60 rather than directly using the information from the internal BMU 25 of a battery pack 20.”; [0083] lines 1-3, “SOC(t) and SOC(t−Δt) are the state of charge of the battery pack at time (t) and (t−Δt), respectively, SOC(t.sub.0) is an initial SOC, Δt is a time interval”). The time interval is the times over which the coulomb count is performed, thereby corresponding to the number of times per second the coulomb count is received. Even if Sharma in view of Gullu and Smedley does not explicitly teach receiving the count at about 0.1 to 10 Hz or times per second, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select a sampling rate of 0.1 to 10 times per second, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 3, Sharma in view of Gullu and Smedley teaches The storage system of claim 1, wherein the state-of-charge estimate of the battery is calculated using Equation (1): SoC = f(Qctot,Vbatt) (Smedley: equation 6), where Qctot = sum(Qc1...QcN) (Smedley: [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”), and the voltage measurement is a battery pack voltage measurement Vbatt ([0026] lines 1-9, “state of charge SOCi may be defined as available charge in a battery cell, expressed as a percentage of present capacity. To estimate the SOCi, a coulomb counting method, based on counting the amount of charge being given to or taken from a cell over change in time, for example, may be relied upon. Cumulative error of estimated SOCi may be corrected using a lookup table LTi representative of a function of the battery terminal voltage Vbi and temperature Ti at a rest state whenever possible.”). Regarding claim 4, Sharma in view of Gullu and Smedley teaches The storage system of claim 1, wherein the power converter comprises four microinverters (Sharma: Fig. 5, BATT #01-04; [0046] lines 4-5, “Each battery pack includes an inverter and a battery management unit (BMU) therein.”; Gullu: microinverter). Regarding claim 5, Sharma in view of Gullu and Smedley teaches The storage system of claim 1, wherein the local coulomb count is performed @ (N-1) Hz, where N is a number of microinverters (Sharma: [0071] lines 6-8, “The BPMU 30 provides real time and reliable data for the system controller 60 rather than directly using the information from the internal BMU 25 of a battery pack 20.”; [0083] lines 1-3, “SOC(t) and SOC(t−Δt) are the state of charge of the battery pack at time (t) and (t−Δt), respectively, SOC(t.sub.0) is an initial SOC, Δt is a time interval”). The time interval is the times over which the coulomb count is performed, thereby corresponding to the number of times per second the coulomb count is received. Even if Sharma in view of Gullu and Smedley does not explicitly teach receiving the count at about 0.1 to 10 Hz or times per second, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select a sampling rate of 0.1 to 10 times per second, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 6, Sharma in view of Gullu and Smedley teaches The storage system of claim 1, wherein the voltage measurement is obtained locally by the battery management unit (Sharma: Fig. 7, step 206; [0090] lines 3-7, “If the sleep time is not set, at block 90, the voltage and the current of each respective battery are checked and recorded. During discharging (represented by “i<−1” in FIG. 8) or charging (represented by “i>1”), the voltage and the current at any time will be kept updated by cycling back to block 90.; [0089] lines 24-25, “Battery pack voltage, average pack temperatures, fail codes, and SOH are also gathered from BMS.”). Regarding claim 7, Sharma in view of Gullu and Smedley teaches The storage system of claim 1, wherein the power converter is one of an AC-DC power converter (Sharma: [0054] lines 9-11, “Power converter 10 is configured to convert direct current (DC) from a respective battery pack 20 to alternating current (AC) or vice versa.”) or a DC-DC power converter. Regarding claim 8, Sharma teaches A method for managing a storage system (Abstract; Fig. 1, system 100) configured for use with an energy management system ([0051] lines 10-13, “System 100 can be used for discharging power from battery packs 20 to a grid 85, or for charging from the grid 85 to battery packs 20.”), comprising: receiving a local coulomb count from each (Fig. 1, inverters 40; [0066] lines 1-5, “In some embodiments, each BPMU 30 is also configured to determine state of health (SOH) of each respective battery pack 20 based on the capacity of the respective battery pack 20. A suitable technique including, but not limited to, Coulomb counting”) of a power converter (power converter 10); obtaining a voltage measurement (Fig. 7, step 206) of a battery (battery 20; Fig. 3; [0057] lines 6-7, “The battery set 27 may include one or more batteries 21”); and calculating a state-of-charge estimate using a calculated ([0081] At step 210, state of charge (SOC) of the respective battery pack 20 is determined and updated based on the initial value of SOC, the current, and the time interval. In some embodiments, a suitable technique such as Coulomb counting, electrochemical impedance measurement, or any other suitable techniques, or a combination thereof is used for determining the SOH and the SOC of each respective battery pack.). The SOC is the state-of-charge estimate. Sharma does not teach the method, comprising: a microinverter; calculating a total battery coulomb count; calculating a state-of-charge estimate using a calculated total battery coulomb count. Gullu teaches an analogous method (Abstract), comprising: a microinverter (Figs. 1 and 5; p. 2 “3-port micro inverter is used. One port is connected to the PV panel as an input, one port that is bidirectional is connected to the battery pack, and another port is connected to the load.”). It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Sharma to substitute the inverters for microinverters because the use of microinverters as inverters is well known in the art and yields predictable results, such as reducing the size of the components. Sharma in view of Gullu does not teach the method, comprising: calculating a total battery coulomb count; calculating a state-of-charge estimate using a calculated total battery coulomb count. Smedley teaches an analogous method (Abstract), comprising: calculate a total battery coulomb count ([0044] lines 1-4, “At reference numeral 708, the process 700 includes the BMC controller 120 calculating a sum S of the battery status signals Bsi. For example, the sum may be determined according to S=.SIGMA..sub.i=1.sup.nBsi.”; [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”), and calculate a state-of-charge estimate using a calculated total battery coulomb count ([0026] lines 1-9, “state of charge SOCi may be defined as available charge in a battery cell, expressed as a percentage of present capacity. To estimate the SOCi, a coulomb counting method, based on counting the amount of charge being given to or taken from a cell over change in time, for example, may be relied upon. Cumulative error of estimated SOCi may be corrected using a lookup table LTi representative of a function of the battery terminal voltage Vbi and temperature Ti at a rest state whenever possible.”; [0031] lines 1-4, “Based on the battery status parameters, each of the BCC controllers 1-n 110 generates a corresponding battery status signal Bsi according to, for example, equation (6) below. Bsi = f ( SOCi - .chi. ) Q i Vbi , where .chi. = { 1 charging 0 discharging”; [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”). It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the method of Sharma in view of Gullu to include the total battery coulomb count of Smedley because the calculation of a total coulomb count of a battery would yield predictable results, such as determining the total coulomb count across the respective battery cells. Regarding claim 9, Sharma in view of Gullu and Smedley teaches The method of claim 8, wherein receiving the local coulomb count occurs at about 0.1 to 10 Hz or times per second (Sharma: [0071] lines 6-8, “The BPMU 30 provides real time and reliable data for the system controller 60 rather than directly using the information from the internal BMU 25 of a battery pack 20.”; [0083] lines 1-3, “SOC(t) and SOC(t−Δt) are the state of charge of the battery pack at time (t) and (t−Δt), respectively, SOC(t.sub.0) is an initial SOC, Δt is a time interval”). The time interval is the times over which the coulomb count is performed, thereby corresponding to the number of times per second the coulomb count is received. Even if Sharma in view of Gullu and Smedley does not explicitly teach receiving the count at about 0.1 to 10 Hz or times per second, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select a sampling rate of 0.1 to 10 times per second, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 10, Sharma in view of Gullu and Smedley teaches The method of claim 8, wherein the state-of-charge estimate of the battery is calculated using Equation (1): SoC = f(Qctot,Vbatt) (Smedley: equation 6), where Qctot = sum(Qc1...QcN) (Smedley: [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”), and the voltage measurement is a battery pack voltage measurement Vbatt ([0026] lines 1-9, “state of charge SOCi may be defined as available charge in a battery cell, expressed as a percentage of present capacity. To estimate the SOCi, a coulomb counting method, based on counting the amount of charge being given to or taken from a cell over change in time, for example, may be relied upon. Cumulative error of estimated SOCi may be corrected using a lookup table LTi representative of a function of the battery terminal voltage Vbi and temperature Ti at a rest state whenever possible.”). Regarding claim 11, Sharma in view of Gullu and Smedley teaches The method of claim 8, wherein the power converter comprises four microinverters (Sharma: Fig. 5, BATT #01-04; [0046] lines 4-5, “Each battery pack includes an inverter and a battery management unit (BMU) therein.”; Gullu: microinverter). Regarding claim 12, Sharma in view of Gullu and Smedley teaches The method of claim 11, wherein the local coulomb count is performed @ (N-1) Hz, where N is a number of microinverters (Sharma: [0071] lines 6-8, “The BPMU 30 provides real time and reliable data for the system controller 60 rather than directly using the information from the internal BMU 25 of a battery pack 20.”; [0083] lines 1-3, “SOC(t) and SOC(t−Δt) are the state of charge of the battery pack at time (t) and (t−Δt), respectively, SOC(t.sub.0) is an initial SOC, Δt is a time interval”). The time interval is the times over which the coulomb count is performed, thereby corresponding to the number of times per second the coulomb count is received. Even if Sharma in view of Gullu and Smedley does not explicitly teach receiving the count at about 0.1 to 10 Hz or times per second, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select a sampling rate of 0.1 to 10 times per second, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 13, Sharma in view of Gullu and Smedley teaches The method of claim 12, wherein the power converter is one of an AC-DC power converter (Sharma: [0054] lines 9-11, “Power converter 10 is configured to convert direct current (DC) from a respective battery pack 20 to alternating current (AC) or vice versa.”) or a DC-DC power converter. Regarding claim 14, Sharma teaches A non-transitory computer readable storage medium having stored thereon instructions ([0096] lines 4-7, “The disclosed methods may also be at least partially embodied in the form of tangible, non-transient machine readable storage media encoded with computer program code.”) that when executed by a processor perform a method for managing a storage system ([0096] lines 11-19, “the computer program code is loaded into and executed by a computer, the computer becomes an apparatus for practicing the method. The methods may also be at least partially embodied in the form of a computer into which computer program code is loaded and/or executed, such that, the computer becomes an apparatus for practicing the methods. When implemented on a general-purpose processor, the computer program code segments configure the processor to create specific logic circuits.”) configured for use with an energy management system ([0051] lines 10-13, “System 100 can be used for discharging power from battery packs 20 to a grid 85, or for charging from the grid 85 to battery packs 20.”), comprising: receiving a local coulomb count from each (Fig. 1, inverters 40; [0066] lines 1-5, “In some embodiments, each BPMU 30 is also configured to determine state of health (SOH) of each respective battery pack 20 based on the capacity of the respective battery pack 20. A suitable technique including, but not limited to, Coulomb counting”) of a power converter (power converter 10); obtaining a voltage measurement (Fig. 7, step 206) of a battery (battery 20; Fig. 3; [0057] lines 6-7, “The battery set 27 may include one or more batteries 21”); and calculating a state-of-charge estimate using a calculated ([0081] At step 210, state of charge (SOC) of the respective battery pack 20 is determined and updated based on the initial value of SOC, the current, and the time interval. In some embodiments, a suitable technique such as Coulomb counting, electrochemical impedance measurement, or any other suitable techniques, or a combination thereof is used for determining the SOH and the SOC of each respective battery pack.). The SOC is the state-of-charge estimate. Sharma does not teach the instructions, comprising: a microinverter; and calculating a state-of-charge estimate using a calculated total battery coulomb count. Gullu teaches an analogous instructions (Abstract), comprising: a microinverter (Figs. 1 and 5; p. 2 “3-port micro inverter is used. One port is connected to the PV panel as an input, one port that is bidirectional is connected to the battery pack, and another port is connected to the load.”). It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Sharma to substitute the inverters for microinverters because the use of microinverters as inverters is well known in the art and yields predictable results, such as reducing the size of the components. Sharma in view of Gullu does not teach the instructions, comprising: calculating a state-of-charge estimate ([0026] lines 1-9, “state of charge SOCi may be defined as available charge in a battery cell, expressed as a percentage of present capacity. To estimate the SOCi, a coulomb counting method, based on counting the amount of charge being given to or taken from a cell over change in time, for example, may be relied upon. Cumulative error of estimated SOCi may be corrected using a lookup table LTi representative of a function of the battery terminal voltage Vbi and temperature Ti at a rest state whenever possible.”; [0031] lines 1-4, “Based on the battery status parameters, each of the BCC controllers 1-n 110 generates a corresponding battery status signal Bsi according to, for example, equation (6) below. Bsi = f ( SOCi - .chi. ) Q i Vbi , where .chi. = { 1 charging 0 discharging”; [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”) using a calculated total battery coulomb count ([0044] lines 1-4, “At reference numeral 708, the process 700 includes the BMC controller 120 calculating a sum S of the battery status signals Bsi. For example, the sum may be determined according to S=.SIGMA..sub.i=1.sup.nBsi.”; [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”). It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the instructions of Sharma in view of Gullu to include the total battery coulomb count of Smedley because the calculation of a total coulomb count of a battery would yield predictable results, such as determining the total coulomb count across the respective battery cells. Regarding claim 15, Sharma in view of Gullu and Smedley teaches The non-transitory computer readable storage medium of claim 14, wherein receiving the local coulomb count occurs at about 0.1 to 10 Hz or times per second (Sharma: [0071] lines 6-8, “The BPMU 30 provides real time and reliable data for the system controller 60 rather than directly using the information from the internal BMU 25 of a battery pack 20.”; [0083] lines 1-3, “SOC(t) and SOC(t−Δt) are the state of charge of the battery pack at time (t) and (t−Δt), respectively, SOC(t.sub.0) is an initial SOC, Δt is a time interval”). The time interval is the times over which the coulomb count is performed, thereby corresponding to the number of times per second the coulomb count is received. Even if Sharma in view of Gullu and Smedley does not explicitly teach receiving the count at about 0.1 to 10 Hz or times per second, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select a sampling rate of 0.1 to 10 times per second, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 16, Sharma in view of Gullu and Smedley teaches The non-transitory computer readable storage medium of claim 14, wherein the state-of-charge estimate of the battery is calculated using Equation (1): SoC = f(Qctot,Vbatt) (Smedley: equation 6), where Qctot = sum(Qc1...QcN) (Smedley: [0025] lines 9-14, “each BCC controller 1-n 110 estimates battery status parameters, such as state of charge SOCi, capacity Qi, state of health SOHi, etc., for the battery cell of its corresponding BCC. Based on the battery status parameters, the BCC controllers 1-n 110 generate a respective battery status signal Bsi which is provided to the BMC controller 120.”), and the voltage measurement is a battery pack voltage measurement Vbatt ([0026] lines 1-9, “state of charge SOCi may be defined as available charge in a battery cell, expressed as a percentage of present capacity. To estimate the SOCi, a coulomb counting method, based on counting the amount of charge being given to or taken from a cell over change in time, for example, may be relied upon. Cumulative error of estimated SOCi may be corrected using a lookup table LTi representative of a function of the battery terminal voltage Vbi and temperature Ti at a rest state whenever possible.”). Regarding claim 17, Sharma in view of Gullu and Smedley teaches The non-transitory computer readable storage medium of claim 14, wherein the power converter comprises four microinverters (Sharma: Fig. 5, BATT #01-04; [0046] lines 4-5, “Each battery pack includes an inverter and a battery management unit (BMU) therein.”; Gullu: microinverter). Regarding claim 18, Sharma in view of Gullu and Smedley teaches The non-transitory computer readable storage medium of claim 17, wherein the local coulomb count is performed @ (N-1) Hz, where N is a number of microinverters (Sharma: [0071] lines 6-8, “The BPMU 30 provides real time and reliable data for the system controller 60 rather than directly using the information from the internal BMU 25 of a battery pack 20.”; [0083] lines 1-3, “SOC(t) and SOC(t−Δt) are the state of charge of the battery pack at time (t) and (t−Δt), respectively, SOC(t.sub.0) is an initial SOC, Δt is a time interval”). The time interval is the times over which the coulomb count is performed, thereby corresponding to the number of times per second the coulomb count is received. Even if Sharma in view of Gullu and Smedley does not explicitly teach receiving the count at about 0.1 to 10 Hz or times per second, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select a sampling rate of 0.1 to 10 times per second, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 19, Sharma in view of Gullu and Smedley teaches The non-transitory computer readable storage medium of claim 18, wherein the power converter is one of an AC-DC power converter (Sharma: [0054] lines 9-11, “Power converter 10 is configured to convert direct current (DC) from a respective battery pack 20 to alternating current (AC) or vice versa.”) or a DC-DC power converter. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to BRIAN GEISS whose telephone number is (571)270-1248. The examiner can normally be reached Monday - Friday 7:30 am - 4:30 pm. 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, Catherine Rastovski can be reached at (571) 270-0349. 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. /B.B.G./Examiner, Art Unit 2857 /Catherine T. Rastovski/Supervisory Primary Examiner, Art Unit 2857
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Prosecution Timeline

Apr 01, 2024
Application Filed
Aug 13, 2026
Non-Final Rejection mailed — §101, §103 (current)

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Expected OA Rounds
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3y 2m (~8m remaining)
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