Prosecution Insights
Last updated: October 04, 2026
Application No. 18/638,869

ENERGY STORAGE SYSTEMS

Non-Final OA §103
Filed
Apr 18, 2024
Priority
May 11, 2023 — provisional 63/465,596
Examiner
VAN OUDENAREN, MATTHEW W
Art Unit
Tech Center
Assignee
Enphase Energy Inc.
OA Round
1 (Non-Final)
78%
Grant Probability
Favorable
1-2
OA Rounds
5m
Est. Remaining
89%
With Interview

Examiner Intelligence

Grants 78% — above average
78%
Career Allowance Rate
543 granted / 700 resolved
+17.6% vs TC avg
Moderate +12% lift
Without
With
+11.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
25 currently pending
Career history
716
Total Applications
across all art units

Statute-Specific Performance

§101
0.6%
-39.4% vs TC avg
§103
55.6%
+15.6% vs TC avg
§102
12.3%
-27.7% vs TC avg
§112
28.1%
-11.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 700 resolved cases

Office Action

§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 § 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. Claims 1-4 are rejected under 35 U.S.C. 103 as being unpatentable over Fukuda (WO 2022/196405, using the equivalent US 2024/0145815 for citation purposes), and further in view of Reis et al. (US 2011/0262793). Regarding Claim 1, Fukuda teaches a battery pack (“energy storage system”) (Abstract). As illustrated in Figures 1-2, Fukuda teaches that the battery pack comprises a monolithic heat-dissipating case (4) (“monolithically formed chassis”) configured to house a battery cell (1) (“battery cell”) ([0066], [0072]). As illustrated in Figure 2, Fukuda teaches that the battery pack comprises a pair of end plates (5) which connect to opposite ends of the heat-dissipating case ([0071]). Fukuda does not explicitly teach that the heat-dissipating case has cooling fins defined thereon, wherein the cooling fins are defined on an exterior of the heat-dissipating case and are configured to provide at least one of active or passive cooling. However, Reis teaches a battery pack (Abstract). As illustrated in Figure 1, Reis teaches that the battery pack comprises a cell box (102) configured to house a battery cell (101), wherein fins (110) are formed on an exterior of the cell box ([0023]). Reis teaches that the fins act as heat sinks to passively increase thermal exchange between the battery cell and the cell box ([0023]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would form the heat-dissipating case of Fukuda such that it includes fins (“cooling fins”), as taught by Reis, on an exterior of the heat-dissipating case (“cooling fins are defined on an exterior of the heat-dissipating case”), given that such cooling fins would function as heat sinks to passively increase thermal exchange between the battery cell and the heat-dissipating case (“at least one of active or passive cooling”). Regarding Claim 2, Fukuda, as modified by Reis, teaches the instantly claimed invention of Claim 1, as previously described. Claim 2 provides further limitations on the system in a scenario wherein the vent/vapor channel is present. However, neither Claim 1 nor Claim 2 explicitly requires that the system includes the vent/vapor channel. Therefore, Fukuda, as modified by Reis, is considered to meet the limitations of Claim 2 by virtue of meeting the limitations of Claim 1, as previously described. Regarding Claim 3, Fukuda, as modified by Reis, teaches the instantly claimed invention of Claim 1, as previously described. Claim 3 provides further limitations on the system in a scenario wherein the vent/vapor channel is present. However, neither Claim 1 nor Claim 3 explicitly requires that the system includes the vent/vapor channel. Therefore, Fukuda, as modified by Reis, is considered to meet the limitations of Claim 2 by virtue of meeting the limitations of Claim 1, as previously described. Regarding Claim 4, Fukuda, as modified by Reis, teaches the instantly claimed invention of Claim 1, as previously described. As previously described (See Claim 1), the battery pack comprises a pair of end plates (“end plates”) which connect to opposite ends of the heat-dissipating case. Claims 5-7 are rejected under 35 U.S.C. 103 as being unpatentable over Fukuda (WO 2022/196405, using the equivalent US 2024/0145815 for citation purposes), and further in view of Reis et al. (US 2011/0262793) and Kano et al. (US 2016/0359153). Regarding Claim 5, Fukuda, as modified by Reis, teaches the instantly claimed invention of Claim 4, as previously described. Fukuda, as modified by Reis, does not explicitly teach that the end plates are configured to mount on a mounting or wiring rail. However, Kano teaches an electric storage device (Abstract). As illustrated in Figures 1, 4-5, Kano teaches that the device comprises a storage module (16), wherein the storage module comprises a plurality of stacked storage cells (22), wherein a pair of end plates (28a, 28b) are disposed at opposite ends of the stacked storage cells ([0023]-[0028]). As illustrated in Figures 1 and 4, Kano teaches that the end plates are mounted to a mounting plate (18a) via fixing screws (34) such that the storage module is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate ([0045]). As illustrated in Figures 1 and 4, Kano teaches that the mounting plate provides a platform for the vertical stacking of an additional storage module ([0023], [0045]). Furthermore, Kano teaches that the mounting plate helps absorb displacement and deformation ([0033], [0045]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would construct the end plates of Fukuda, as modified by Reis, such that they are each mounted to a mounting plate (“mounting or wiring rail”) via fixing screws such that the battery pack is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate, as taught by Kano, given that such a mounting plate would provide a platform for the vertical stacking of an additional battery pack and also help absorb displacement and deformation. Regarding Claim 6, Fukuda, as modified by Reis and Kano, teaches the instantly claimed invention of Claim 5, as previously described. As previously described (See Claim 5), the end plates of Fukuda, as modified by Reis and Kano, are each mounted to a mounting plate via fixing screws such that the battery pack is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate. Accordingly, the end plates are interpreted to be, at least in part, configured to mount on the mounting plate in a vertical orientation insofar as the battery pack is displaced vertically (i.e. underneath) the upper portion of the mounting plate. Regarding Claim 7, Fukuda, as modified by Reis and Kano, teaches the instantly claimed invention of Claim 5, as previously described. As previously described (See Claim 5), the end plates of Fukuda, as modified by Reis and Kano, are each mounted to a mounting plate via fixing screws such that the battery pack is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate. Accordingly, the end plates are interpreted to be, at least in part, configured to mount on the mounting plate in a horizontal orientation insofar as the battery pack is displaced horizontally (i.e. next to) the downward extending side portion of the mounting plate. Claims 8-11 are rejected under 35 U.S.C. 103 as being unpatentable over Fukuda (WO 2022/196405, using the equivalent US 2024/0145815 for citation purposes), and further in view of Reis et al. (US 2011/0262793) and Zimmanck (US 2021/0296903). Regarding Claim 8, Fukuda teaches a battery pack (“energy storage system”) (Abstract). As illustrated in Figures 1-2, Fukuda teaches that the battery pack comprises a monolithic heat-dissipating case (4) (“monolithically formed chassis”) configured to house a battery cell (1) (“battery cell”) ([0066], [0072]). As illustrated in Figure 2, Fukuda teaches that the battery pack comprises a pair of end plates (5) which connect to opposite ends of the heat-dissipating case ([0071]). Fukuda does not explicitly teach that the heat-dissipating case has cooling fins defined thereon, wherein the cooling fins are defined on an exterior of the heat-dissipating case and are configured to provide at least one of active or passive cooling. However, Reis teaches a battery pack (Abstract). As illustrated in Figure 1, Reis teaches that the battery pack comprises a cell box (102) configured to house a battery cell (101), wherein fins (110) are formed on an exterior of the cell box ([0023]). Reis teaches that the fins act as heat sinks to passively increase thermal exchange between the battery cell and the cell box ([0023]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would form the heat-dissipating case of Fukuda such that it includes fins (“cooling fins”), as taught by Reis, on an exterior of the heat-dissipating case (“cooling fins are defined on an exterior of the heat-dissipating case”), given that such cooling fins would function as heat sinks to passively increase thermal exchange between the battery cell and the heat-dissipating case (“at least one of active or passive cooling”). Fukuda, as modified by Reis, does not explicitly teach that the battery pack is connected to a power conditioner of an energy management system comprising a distributed energy resource comprising the power conditioner connected to a distributed energy resource controller. However, Zimmank teaches a microgrid member (152-1) ([0020]). As illustrated in Figure 1, Zimmank teaches that the microgrid member comprises a distributed energy resource (106) comprising a power conditioner (110) connected to both a distributed energy resource controller (108) and an energy storage device (112) ([0026]-[0027], [0030]). Zimmank teaches that the energy storage device is operable to both store energy generated by the microgrid member and in turn convert said energy to commercial power grid compliant AC power ([0027]). Zimmank teaches that the microgrid member helps generate power as an intentional island without imposing safety risks, for example, on any line works that may be working on a utility grid ([0003]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would connect the battery pack of Fukuda, as modified by Reis, to a power conditioner in a microgrid member (“energy management system”) comprising a distributed energy resource comprising the power conditioner connected to both a distributed energy resource controller and the battery pack, as taught by Zimmank, given that the battery pack would be operable to store energy generated by the microgrid member and in turn convert said energy to commercial power grid compliant AC power so as to help the microgrid member generate power as an intentional island without imposing safety risks, for example, on any line works that may be working on a utility grid. Regarding Claim 9, Fukuda, as modified by Reis and Zimmank, teaches the instantly claimed invention of Claim 8, as previously described. Claim 9 provides further limitations on the system in a scenario wherein the vent/vapor channel is present. However, neither Claim 8 nor Claim 9 explicitly requires that the system includes the vent/vapor channel. Therefore, Fukuda, as modified by Reis, is considered to meet the limitations of Claim 9 by virtue of meeting the limitations of Claim 8, as previously described. Regarding Claim 10, Fukuda, as modified by Reis and Zimmank, teaches the instantly claimed invention of Claim 8, as previously described. Claim 10 provides further limitations on the system in a scenario wherein the vent/vapor channel is present. However, neither Claim 8 nor Claim 10 explicitly requires that the system includes the vent/vapor channel. Therefore, Fukuda, as modified by Reis, is considered to meet the limitations of Claim 10 by virtue of meeting the limitations of Claim 8, as previously described. Regarding Claim 11, Fukuda, as modified by Reis and Zimmank, teaches the instantly claimed invention of Claim 8, as previously described. As previously described (See Claim 8), the battery pack comprises a pair of end plates (“end plates”) which connect to opposite ends of the heat-dissipating case. Claims 12-14 are rejected under 35 U.S.C. 103 as being unpatentable over Fukuda (WO 2022/196405, using the equivalent US 2024/0145815 for citation purposes), and further in view of Reis et al. (US 2011/0262793) and Zimmanck (US 2021/0296903) and Kano et al. (US 2016/0359153). Regarding Claim 12, Fukuda, as modified by Reis and Zimmank, teaches the instantly claimed invention of Claim 11, as previously described. Fukuda, as modified by Reis and Zimmank, does not explicitly teach that the end plates are configured to mount on a mounting or wiring rail. However, Kano teaches an electric storage device (Abstract). As illustrated in Figures 1, 4-5, Kano teaches that the device comprises a storage module (16), wherein the storage module comprises a plurality of stacked storage cells (22), wherein a pair of end plates (28a, 28b) are disposed at opposite ends of the stacked storage cells ([0023]-[0028]). As illustrated in Figures 1 and 4, Kano teaches that the end plates are mounted to a mounting plate (18a) via fixing screws (34) such that the storage module is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate ([0045]). As illustrated in Figures 1 and 4, Kano teaches that the mounting plate provides a platform for the vertical stacking of an additional storage module ([0023], [0045]). Furthermore, Kano teaches that the mounting plate helps absorb displacement and deformation ([0033], [0045]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would construct the end plates of Fukuda, as modified by Reis and Zimmank, such that they are each mounted to a mounting plate (“mounting or wiring rail”) via fixing screws such that the battery pack is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate, as taught by Kano, given that such a mounting plate would provide a platform for the vertical stacking of an additional battery pack and also help absorb displacement and deformation. Regarding Claim 13, Fukuda, as modified by Reis and Zimmank and Kano, teaches the instantly claimed invention of Claim 12, as previously described. As previously described (See Claim 12), the end plates of Fukuda, as modified by Reis and Zimmank and Kano, are each mounted to a mounting plate via fixing screws such that the battery pack is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate. Accordingly, the end plates are interpreted to be, at least in part, configured to mount on the mounting plate in a vertical orientation insofar as the battery pack is displaced vertically (i.e. underneath) the upper portion of the mounting plate. Regarding Claim 14, Fukuda, as modified by Reis and Zimmank and Kano, teaches the instantly claimed invention of Claim 12, as previously described. As previously described (See Claim 12), the end plates of Fukuda, as modified by Reis and Kano, are each mounted to a mounting plate via fixing screws such that the battery pack is positioned under an upper portion of the mounting plate and displaced horizontally from a downward extending side portion of the mounting plate. Accordingly, the end plates are interpreted to be, at least in part, configured to mount on the mounting plate in a horizontal orientation insofar as the battery pack is displaced horizontally (i.e. next to) the downward extending side portion of the mounting plate. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MATTHEW W VAN OUDENAREN whose telephone number is (571)270-7595. The examiner can normally be reached 7AM-3PM EST M-F. 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, Matthew Martin can be reached at 5712707871. 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. /MATTHEW W VAN OUDENAREN/Primary Examiner, Art Unit 1728
Read full office action

Prosecution Timeline

Apr 18, 2024
Application Filed
Aug 31, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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3y 11m to grant Granted Sep 15, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
78%
Grant Probability
89%
With Interview (+11.8%)
2y 11m (~5m remaining)
Median Time to Grant
Low
PTA Risk
Based on 700 resolved cases by this examiner. Grant probability derived from career allowance rate.

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