Prosecution Insights
Last updated: October 02, 2026
Application No. 18/644,104

ENERGY STORAGE SYSTEM

Non-Final OA §102§103§112§DOUBLEPATENT
Filed
Apr 24, 2024
Priority
May 19, 2023 — RE 10-2023-0065148
Examiner
MALONEY, MICHAEL PATRICK
Art Unit
Tech Center
Assignee
SK Inc.
OA Round
1 (Non-Final)
Grant Probability
Favorable
1-2
OA Rounds

Examiner Intelligence

Grants only 0% of cases
0%
Career Allowance Rate
0 granted / 0 resolved
-60.0% vs TC avg
Minimal +0% lift
Without
With
+0.0%
Interview Lift
resolved cases with interview
Typical timeline
Avg Prosecution
18 currently pending
Career history
1
Total Applications
across all art units
This examiner has no resolved cases yet (career too new); statute-level performance unavailable. The Grant Probability card shows Tech Center averages instead.

Office Action

§102 §103 §112 §DOUBLEPATENT
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 . Examiner Note It is noted that all references hereinafter to Applicant’s specification are to the published application US 20240387924 A1 unless otherwise stated. Additionally, any italicized, bolded, or underlined text utilized hereinafter is to be interpreted as emphasis placed thereupon. Information Disclosure Statement The information disclosure statements (IDS) submitted on 31 March 2025, 01 July 2025, and 04 February 2026 are in compliance with 37 CFR 1.97, 1.98, and have been considered. Claim Interpretation Claim 12 recites the term “electronic component”. Paragraph [0089] of the specification provides the following definition, “Examples of the electronic component may include various types of sensors including a temperature sensor and a voltage sensor, a signal transmission device, various control devices including a battery management system (BMS), and a circuit board connected thereto. However, the electronic component is not limited to the above component and may be understood as a general term for an electrical component necessary for the smooth use and maintenance of the energy storage system”. As such, the term “electronic component” is being interpreted in the manner set forth by the specification. Claim Objections Claim 2 is objected to because of the following informalities: The claim recites “the outlet is open in the top frame toward the bottom frame”. However, the claim language is unclear. The examiner therefore politely suggests wording the claim so as to read “the outlet is open in the top frame in a direction from the top frame toward the bottom frame”. Claim 11 is objected to because of the following informalities: The claim recites “a fire extinguishing portion extinguishing a flame occurring in the internal space of the cabinet”. However, the claim language is unclear as to whether the flame occurring in the internal space of the cabinet is necessary for the fire extinguishing portion to exist. The examiner therefore politely suggests wording the claim so as to read “a fire extinguishing portion capable of extinguishing a flame occurring in the internal space of the cabinet”. 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 13 and 16 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. Regarding Claim 13, The term “a temperature of a preset temperature” in claim 13 is a relative term which renders the claim indefinite. The term “a temperature of a preset temperature” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. It is noted that the broadest reasonable interpretation of the term “a temperature of a preset temperature”, within the context of the claim, is any stable temperature in which a fire extinguishing agent exists in a solid state. Thus, any temperature higher than the stable temperature allows for formation of the aerosol. Regarding Claim 16, The term “retrievable” in claim 16 is a relative term which renders the claim indefinite. The term “retrievable” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. It is noted that the broadest reasonable interpretation of the term “retrievable” within the context of the claim is any manner in which the battery modules can be removed and reinserted within the cabinet housing without compromising the integrity of said housing. Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. Claim 16 is provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claim 19 of copending Application No. 18/644,110 in view of Kronke et al. (US 20170077467 A1, “Kronke”). This is a provisional nonstatutory double patenting rejection. Regarding Claim 16, claim 19 of the copending application ‘110 discloses all limitations of the energy storage system as disclosed in claim 16 of the instant application except for the energy storage system comprising a cabinet including a housing. Kronke discloses an energy storage system comprising a lower housing and upper housing ([0026]) which is contained within an enclosed space and accessed via a door (i.e. a cabinet, see Figures 1 and 4). Copending application ‘110 and Kronke are analogous art as both pertain to energy storage systems. Therefore, it would have been obvious to a person of ordinary skill in the art to house the energy storage system with an enclosed space (i.e. a cabinet) so as to better control the internal temperature and conditions of the batteries and to further protect the batteries from the outside environment. Furthermore, the transitional term "comprising", which is synonymous with "including," "containing," or "characterized by," is inclusive or open-ended and does not exclude additional, unrecited elements or method steps. See, e.g., Mars Inc. v. H.J. Heinz Co., 377 F.3d 1369, 1376, 71 USPQ2d 1837, 1843 (Fed. Cir. 2004), MPEP 2111.03. As such, claim 16 of the instant application is not patentably distinct from claim 19 of the copending application. 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. Claims 1 and 15 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Hessmer and Podzuweit (EP 4274008 A1, “Hessmer”). Regarding Claim 1,, Hessmer discloses a container for storing batteries (i.e. an energy storage system, see [0012] and Figure 1) wherein the container has a container body which encloses a storage space, or in other words, the container is hollow (i.e. a cabinet, [0013]). The storage space has a plurality of storage planes in which the batteries can be stored (i.e. a mounting portion capable of mounting a plurality of battery modules thereon, [0013]-[0014], see Figure 4). The container also includes a door element which can be opened and closed (i.e. a door member capable of being opened and closed, [0016], see Figure 4). PNG media_image1.png 680 825 media_image1.png Greyscale Figure 4, Annotated by the Examiner The container further includes a pressure relief device (i.e. a venting portion, [0023], see Figures 5 and 6) which allows the internal atmosphere of the container body to communicate with the pressure relief device via a pressure relief opening (i.e. the venting portion includes at least one inlet communicating with the internal space and allowing the gas to flow into the inlet, Figures 5 and 6, [0089]) and the filtered gases then leave the pressure relief device via the holes of the perforated plate into the environment (i.e. at least one outlet disposed in an outer surface of the cabinet and communicating with the inlet; see gas flow 25 in figures 5 and 6, see further [0089]). PNG media_image2.png 420 640 media_image2.png Greyscale Figure 6, Annotated by the Examiner Regarding Claim 15, Hessmer discloses two insertion openings arranged parallel into which fork prongs of a forklift can engage in order to be able to transport and position the container (i.e. a plurality of lifting holes disposed in the cabinet and allowing a transport device to be inserted into the holes, see [0075] and 21 in Figure 1). 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. 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 2-4 are rejected under 35 U.S.C. 103 as being unpatentable over Hessmer. Regarding Claim 2, Hessmer discloses the container as including a cover element which is disposed above the storage space (i.e. a top frame disposed above the mounting portion, [0042]-[0043], see 12 in Figure 4 as residing above the storage portion) and a floor element disposed below the storage space (i.e. a bottom frame disposed below the mounting portion, see 11 in Figure 4 as residing below the storage portion). However, Hessmer does not disclose the perforated plate (i.e. the outlet) as being fixed within the top frame, instead the perforated plate resides above the cover element and is open towards the floor element (i.e. toward the bottom frame, see Figure 4). It would have been obvious to one having ordinary skill in the art at the time the invention was made to modify the cover element of the container to include the perforated plate (i.e. the outlet) rather than being disposed above the cover element, since it has been held that rearranging parts of an invention involves only routine skill in the art. In re Japikse, 86 USPQ 70. The location of the outlet is inconsequential so long as it is above the storage space of the container to allow for the gas flow of the atmosphere within the container to escape. Regarding Claims 3 and 4, Hessmer discloses the container as including the door element as facing the storage space in a first direction (i.e. the door member faces the mounting portion in a first direction. see Figure 4 as annotated below, specifically the face of the door that, when closed, opposes the storage space). The cover element includes a first surface facing the second direction of the door element (i.e. the top frame includes a first surface facing the door member in a second direction, perpendicular to the first direction; see Figure 4 as annotated below, specifically the second direction of the door is the top surface of the door, which opposes the bottom surface of the cover element which is the first direction). PNG media_image3.png 727 842 media_image3.png Greyscale Figure 4, Annotated by the Examiner However, Hessmer does not disclose the outlet as being disposed on the bottom surface of the cover element (i.e. the outlet is disposed in the first surface). As discussed above, it would have been obvious to one having ordinary skill in the art at the time the invention was made to modify the cover element of the container to include the perforated plate (i.e. the outlet) on the first surface rather than being disposed above the cover element, since it has been held that rearranging parts of an invention involves only routine skill in the art. In re Japikse, 86 USPQ 70. The location of the outlet is inconsequential so long as it is above the storage space of the container to allow for the gas flow of the atmosphere within the container to escape. As such, introduction of the outlet into the first surface of the cover element is a matter of design. The introduction of the perforated plate onto the first surface of the cover element would therefore communicate with the separation space between the first surface of the cover assembly and the door element (see Figure 4, as annotated below). PNG media_image4.png 390 963 media_image4.png Greyscale Figure 4, Zoomed in and Annotated by the Examiner Claims 5-7 are rejected under 35 U.S.C. 103 as being unpatentable over Hessmer in view of Lan (CN 219610554 U, machine translation used hereafter). Regarding claims 5-7, Hessmer discloses a cover element (i.e. a top frame) but is silent regarding the top frame as including a hollow portion communicating with the inlet and the outlet. Lan discloses an energy storage battery frame for an energy storage system ([0029]) which includes a frame body composed of multiple columns, crossbeams, and longitudinal beams ([0029]). The frame further includes a hollow heat dissipation duct that features an air inlet and an air outlet ([0030]). Hessmer and Lan each constitute prior art which is directly analogous to the claimed invention: energy storage containers. Therefore, in view of the combined teachings of the prior art, it would have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to modify the cover element of Hessmer to include a hollow portion with both inlets and outlets so as to allow air flow between the internal and external atmospheres of the energy storage device (i.e. the top frame includes a hollow portion communicating with each of the inlet and the outlet, see [0030] of Lan and Figure 4 of Hessmer). As such, following the analysis provided above regarding the outlet as being disposed on a first surface, Hessmer in view of Lan discloses the inlet as being disposed on a second surface of the cover element which is perpendicular to the first surface on the side communicating with the internal storage space of the container, so as to facilitate gas exchange between the internal and external atmosphere (i.e. the top frame further includes a second surface exposed to the internal space, and the inlet is disposed in the second surface, see annotated Figure 4 below, though the internal space is unable to explicitly shown). PNG media_image5.png 363 804 media_image5.png Greyscale Figure 4, Annotated by the Examiner Furthermore, following the analysis above regarding the first and second directions, Hessmer in view of Lan discloses the inlets and outlets as extending in a third direction perpendicular to the first/second direction plane (i.e. it extends in a length direction along the cover assembly). This is already evident in the cover assembly as shown in Figure 4 of Hessmer, and modification as detailed above, would result in the inlets and outlets extending along the length of the cover assembly (i.e. the at least one inlet or the at least one outlet is disposed in a third direction, perpendicular to both the first direction and the second direction, see annotated Figure 4 below). PNG media_image6.png 778 832 media_image6.png Greyscale Figure 4 of Hessmer, Annotated by the Examiner Claims 8 and 11-14 are rejected under 35 U.S.C. 103 as being unpatentable over Hessmer in view of Kronke. Regarding Claim 8, Hessmer discloses an energy storage container but is silent regarding the door member as including a cooling device and at least one inlet and outlet. Kronke discloses a modular energy storage system wherein a cooling device is removably coupled to an outer portion or surface of the door panel and includes openings that correspond with the air return inlet and the air outlet of the cooling device (i.e. the door member further includes a cooling device capable of supplying a cooling medium to the internal space, and at least one of the inlet and the outlet is disposed in the door member, see [0033]-[0034]). Hessmer and Kronke each constitute prior art which is directly analogous to the claimed invention: energy storage systems. Therefore, in view of the combined teachings of the prior art, it would have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to modify the door element of Hessmer with the cooling device as described by Kronke so as to provide a temperature control and thermal management to the internal space of the energy storage system to cool the batteries. In this way, the system has improved thermal management, which can reduce the likelihood of equipment failures, extend the life of one or more energy storage devices, reduce auxiliary power consumption from the system, and improve operating performance of the system (see [0024] of Kronke). Regarding Claim 11, Hessmer is silent regarding a fire extinguishing component of the energy storage system. Kronke discloses a fire suppression system that can an automatically control or extinguish fires within the modular energy storage system (i.e. a fire extinguishing portion extinguishing a flame occurring in the internal space of the cabinet, [0057]). Furthermore, Kronke discloses a shroud which can close off the partial enclosure or cavity defined by the air distribution member and the door panel (i.e. a guide portion dividing a front space formed between the plurality of battery modules and the door member into a plurality of regions, [0040]). Hessmer and Kronke each constitute prior art which is directly analogous to the claimed invention: energy storage systems. Therefore, in view of the combined teachings of the prior art, it would have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to include the fire suppression system and shroud of Kronke so as to provide a means to prevent and/or extinguish fires that breakout within the container ([0057]) and to include the shroud which can help to isolate or seal off the cold aisle cooling area between the energy storage devices and the door assembly ([0042]), respectively. Regarding claim 12, Hessmer in view of Kronke discloses the energy storage system including the fire suppression system wherein one or more temperature monitoring devices (e.g., sensors, etc.) are operatively coupled to, for example, energy storage devices contained within the lower housing of the system and/or within the cold aisle cooling areas and the hot aisle area (i.e. the fire extinguishing portion and the electronic component are disposed together in one of the plurality of regions divided by the guide portion, [0057]). However, Hessmer in view of Kronke is silent regarding the electronic component as being disposed on the inside of the door member. It would have been obvious to one having ordinary skill in the art at the time the invention was made to modify the position of the temperature monitoring devices (i.e. the electronic device) so as to be located on the door member on either side of the shroud rather than being located in the lower housing, since it has been held that rearranging parts of an invention involves only routine skill in the art. In re Japikse, 86 USPQ 70. As such, the location of the sensor is inconsequential in the design of the fire suppression system, so long as the sensor is in communication with the fire suppression system to ensure proper function. Regarding Claim 13, Hessmer in view of Kronke discloses that, in the event that the temperature data exceeds a threshold value to indicate a overheating condition, the fire suppression system will act to extinguish/control a fire or other event relating to an overheating condition of the energy storage devices. The fire suppression system can be a sprinkler system, a gaseous fire suppression system, or a condensed aerosol fire suppression system (i.e. the fire extinguishing portion includes a fire extinguishing agent maintaining a solid state at a temperature of a preset temperature or less and having an aerosol form at a temperature of the preset temperature or more, see [0057]). The condensed aerosol fire suppression system is taken to be a particle based agent, which maintains at a solid state until the temperature data exceeds said threshold value where it will dispense as an aerosol with an inert gas or liquid. Regarding Claim 14, Hessmer is silent regarding the cabinet having a partition dividing the internal space, as well as, the plurality of battery modules as being disposed on both sides of the partition in a height direction of the cabinet. Kronke discloses an energy storage system wherein the container includes partitions that divide the internal space, wherein parallel stacks of battery modules are disposed on either side of the partition and extend in a height direction (see Figures 1 and 4, annotated below). PNG media_image7.png 319 529 media_image7.png Greyscale Figure 1 of Kronke, Annotated by the Examiner PNG media_image8.png 426 553 media_image8.png Greyscale Figure 7 of Kronke, Annotated by the Examiner Hessmer and Kronke each constitute prior art which is directly analogous to the claimed invention: energy storage systems. Therefore, in view of the combined teachings of the prior art, it would have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to include partitions between the vertical stacks of battery modules so as direct and distribute air flow within the system, and in this way the system has improved thermal management, which can reduce the likelihood of equipment failures, extend the life of one or more energy storage devices, reduce auxiliary power consumption from the system, and improve operating performance of the system ([0024] of Kronke). The benefits of the partitions as disclosed by Kronke and discussed above, renders it obvious to divide the battery modules into uniform rows and columns via partitions so as to ensure uniform cooling of the battery modules and adequate air recycling within the cabinet. Furthermore, there are a finite number of ways to organize the batteries within said cabinet; and a person of ordinary skill in the art would have fine-tuned the organization of the batteries therein to ensure adequate air-distribution and recycling and arrived at the preferred selection of using partitions as disclosed by Kronke. “A person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense. In that instance the fact that a combination was obvious to try might show that it was obvious under § 103.” KSR, 550 U.S. at 421, 82 USPQ2d at 1397. Furthermore, it is not necessary that the prior art suggest expressly, or in so many words, the changes or possible improvements the inventor made but that the knowledge be clearly present. In re Sernaker, 217 USPQ 1 (Fed. Cir. 1983). Claims 9 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over Hessmer in view of Kronke as applied to claims 8, 11-14 above, and further in view of Song et al. (KR 102659500 B1, machine translation used hereafter, “Song”). Regarding Claims 9 and 10, Hessmer in view of Kronke discloses the energy storage device including a cooling device (see analysis of claim 8 above). However, Hessmer in view of Kronke is silent regarding the cooling device as including a drain pipe. Song discloses a cooling device for energy storage system ([0017]) which includes a drain section including a drain pipe (i.e. the cooling device includes a drain pipe, [0055]) that allows for dew that accumulates to be discharged to the outside of the container (i.e. allowing condensate occurring in the cooling device to flow, [0054]-[0055]). Further, the outer case of the cooling device includes a first intake port, which is an inlet for recirculating the air of the internal space of the container, and a first discharge port, which is an outlet for discharging internal air that has been cooled by heat exchange with the evaporator back into the internal space (i.e. the inlet and the outlet communicate with the drain pipe, see [0032], [0053], and [0054]). Furthermore, one end of the drain pipe is connected to an inlet port and the other end of the drain pipe is connected to an outlet port (i.e. the inlet is disposed in one end of the drain pipe, and the outlet is disposed in the other end of the drain pipe, see [0055]). Hessmer, Kronke, and Song each constitute prior art which is directly analogous to the claimed invention: energy storage systems. Therefore, in view of the combined teachings of the prior art, it would have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to modify the cooling device of Kronke to include a drain pipe that collects dew (i.e. condensate) that falls from the surface of the evaporator (i.e. a core component of a cooling device) when heat is exchanged between the evaporator and the internal air and discharges the drain to the outside ([0054] of Song). Inclusion of the drain pipe points to a deleterious effect of water within the energy storage cabinet, and as such, it is pertinent to exclude water that is generated from the cooling device. It is well settled that the significance of evidence that a problem was known in the prior art is that knowledge of a problem provides a reason or motivation for workers in the art to apply their skill to its solution. In re Nomiya, 509 F.2d 566, 574, 184 USPQ 607, 613 (CCPA 1975). Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Hessmer in view of Yang et al. (CN 113629339 A, machine translation used hereafter, “Yang”). Regarding Claim 16, Hessmer discloses an energy storage system, as detailed above, including a container that includes an internal space where the batteries are stored (i.e. a cabinet including a housing, see Figure 4). The battery modules are introduced into the storage space so that they can be removed (i.e. a plurality of battery modules inserted in a retrievable way inside a plurality of a corresponding number of receiving spaces defined inside the housing, see [0076] and [0013]). The battery modules are arranged within the storage space in 3 columns and at least 2 rows (i.e. the plurality of battery modules forming at least two columns and at least two rows, see 100 in Figure 4). A door element is arranged in the loading and unloading opening and can be opened and closed (i.e. a door member movably coupled to the housing for opening and closing the housing, [0016] and Figure 4). Further, the plurality of batteries are electrically connected to a charging device (i.e. the plurality of battery modules inside the housing are electrically connected, [0064]). Hessmer however is silent regarding at least one connecting portion as being positioned on an outside surface of the housing for electrically connecting the energy storage system with another energy storage system. Yang discloses an energy storage system (figure 1, [0039]) which features an electrical connection that connects at least two energy storage modules in a manner that is entirely located outside the housing (i.e. at least one connecting portion positioned on an outside surface of the housing for electrically connecting the energy storage system with another energy storage system, [0064]-[0065], see 20 in Figures 1 and 2). Hessmer and Yang each constitute prior art which is directly analogous to the claimed invention: energy storage systems. Therefore, in view of the combined teachings of the prior art, it would have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to electrically connect multiple energy storage systems to provide the required electrical energy and avoids the electrical connection part occupying too much space inside the independent housing, thus improving the energy density of the energy storage system ([0064]-[0065]). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL P MALONEY whose telephone number is (571)270-1730. The examiner can normally be reached M-Th: 7:30a-5p, F: 7:30a-4p. 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, Aaron Austin can be reached at (571) 272-8935. 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. /MICHAEL PATRICK MALONEY/Examiner, Art Unit 1782 /AARON AUSTIN/Supervisory Patent Examiner, Art Unit 1782
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Prosecution Timeline

Apr 24, 2024
Application Filed
Sep 24, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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