Prosecution Insights
Last updated: October 02, 2026
Application No. 18/712,255

ENERGY STORAGE CELL, ARRAY OF ENERGY STORAGE CELLS, AND MANUFACTURING PROCESS

Non-Final OA §102§103§112
Filed
May 22, 2024
Priority
Nov 24, 2021 — EU 21210297.4 +1 more
Examiner
CREPEAU, JONATHAN
Art Unit
Tech Center
Assignee
VARTA Microbattery GmbH
OA Round
1 (Non-Final)
73%
Grant Probability
Favorable
1-2
OA Rounds
9m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
686 granted / 939 resolved
+13.1% vs TC avg
Strong +18% interview lift
Without
With
+18.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
29 currently pending
Career history
960
Total Applications
across all art units

Statute-Specific Performance

§101
1.0%
-39.0% vs TC avg
§103
48.0%
+8.0% vs TC avg
§102
20.5%
-19.5% vs TC avg
§112
21.9%
-18.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 939 resolved cases

Office Action

§102 §103 §112
Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . DETAILED ACTION Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 4, 5, 6, 8, 9, 11, and 12 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. Claims 4, 5, 6, 8, 9, 11, and 12 each recite limitations recited in the alternative (“at least one of….and/or”). However, the later recited alternatives in each claim do not properly stand alone; that is, they require the presence of previously recited limitations for antecedent basis or for proper context. Consequently, the scope of the claims cannot be ascertained. As an example, claim 4 recites “the first layer…and/or the second layer” in the second and third clauses in lines 7-10. However, “a first layer” and “a second layer” are recited as part of the first clause, which is optional, in lines 3-5. If the second and third clauses are considered on their own, they lack proper antecedent basis and context. Further, in the case of claim 4, the last two limitations cannot both be present at the same time, because there can be only one cut edge on the opening edge. If the second and third limitations are both present, this encompasses two cut edges (101g in the specification and drawings), which is not possible. 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. Claims 1 and 3-9 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by JP 2012174523. Regarding claim 1, the reference is directed to an energy storage cell comprising a cylindrical electrode separator assembly (Fig. 1), an airtight and liquid tight housing comprising a metallic housing cup (61) with a terminal circular opening and comprising a bottom, a central section, and a closure section, a lid assembly with a circular edge (62) closing the terminal circular opening (Fig. 2), an annual seal (69) that encloses the edge of the lid assembly and insulates the housing cup and the lid assembly from each other, the central section being cylindrical, the winding shell of the electrode separator assembly contacting an inside of the metallic housing cup in the central section (Fig. 1), wherein in the closure section, the seal is in press contact with the lid assembly and the inside of the housing cup, wherein in the closure section the cup has an opening edge that defines the circular opening, and is bent radially inwards over the circular edge (Fig. 2), wherein a wall thickness of the radially inwardly bent opening edge is greater than a wall thickness of the central section (Fig. 2). Regarding claim 3, the radially bent inward edge is double-layered, is formed by folding, and is U-shaped. Regarding claim 4, the radially bent inward edge has a first layer in direct contact with the annular seal, and a second layer parallel to the first layer on a side of the first layer facing away from the annular seal, the first layer having a cut edge facing radially outwards (Fig. 2). Regarding claim 5, the inwardly bent opening edge comprises a first, inner side in direct contact with the annular seal and a second side facing away from the annular seal. Regarding claim 6, the central section and the closure section are separated by an indentation (61g) that circumferentially surrounds an outside of the housing cup. Regarding claim 7, the annular seal comprises three segments as claimed (Fig. 2). Regarding claim 8, the anode comprises an anode current collector having a first longitudinal edge (23) and a second longitudinal edge parallel thereto (Fig. 1). Regarding claim 9, a contact plate (72) (Fig. 1, [0028]) is welded to the first longitudinal edge of the negative (anode) current collector and covers a first terminal end face of the electrode separator assembly. Thus, the instant claims are anticipated. 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 1-7, 11 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Seefeldt et al (US 20190273223). Regarding claim 1, the reference is directed to an energy storage cell comprising a cylindrical electrode separator assembly (Fig. 1), an airtight and liquid tight housing comprising a metallic housing cup (2) with a terminal circular opening and comprising a bottom, a central section, and a closure section, a lid assembly with a circular edge (8) closing the terminal circular opening (Fig. 4), an annual seal (12) that encloses the edge of the lid assembly and insulates the housing cup and the lid assembly from each other, the central section being cylindrical, wherein in the closure section, the seal is in press contact with the lid assembly and the inside of the housing cup, wherein in the closure section the cup has an opening edge that defines the circular opening, and is bent radially inwards over the circular edge (Fig. 4), wherein a wall thickness of the radially inwardly bent opening edge is greater than a wall thickness of the central section (Fig. 2). Regarding claim 2, the wall thickness of the radially inwardly bent opening edge is thicker than the wall thickness of the central section by a factor of 2 (Fig. 3). Regarding claim 3, the radially bent inward edge is double-layered, is formed by folding, and is U-shaped. Regarding claim 4, the radially bent inward edge has a first layer in direct contact with the annular seal, and a second layer parallel to the first layer on a side of the first layer facing away from the annular seal, the first layer having a cut edge facing radially outwards (Fig. 4). Regarding claim 5, the inwardly bent opening edge comprises a first, inner side in direct contact with the annular seal and a second side facing away from the annular seal. Regarding claim 6, the central section and the closure section are separated by an indentation (13) that circumferentially surrounds an outside of the housing cup. Regarding claim 7, the annular seal comprises three segments as claimed (Fig. 4). Regarding claim 11, the lid assembly comprises a disk (Fig. 4, see notches in element below element “8”), that bursts outwardly in the event of overpressure within the housing. The reference does not expressly teach that the winding shell of the electrode separator assembly contacts an inside of the metallic housing cup in the central section as recited in claim 1. However, the invention as a whole would have been obvious to one skilled in the art at the time of filing because this configuration is well-known in cylindrical wound battery cells. As such, while the feature is not explicitly shown in Seefeldt, it would have been obvious to employ it in the battery of the reference. Regarding claim 12, although the material of the annular sealing member is not specified, it would have been obvious to one skilled in the art to use a material having high heat resistance, that is, a melting point of 300C or above as claimed. It is known to use such engineered plastic materials in battery cells to maintain structural integrity in the event of a rapid increase in temperature. Claims 8 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over Seefeldt et al as applied to claims 1-7, 11 and 12 above, and further in view of Phillips (US 20110086252). Seefeldt et al. does not expressly teach the anode comprises an anode current collector having a first longitudinal edge and a second longitudinal edge parallel thereto (claim 8), or that the first longitudinal edge of the anode current collector sits directly on a bottom of the housing cup and is connected to it by welding (claim 10). Phillips et al. is directed to a cylindrical cell with uncoated portions of the current collector of one polarity (210) directly in contact with a bottom of the case. Therefore, the invention as a whole would have been obvious to one skilled in the art at the time of filing because a particular known technique (current collector of wound electrode body directly contacting case bottom) was recognized as part of the ordinary capabilities of one skilled in the art. KSR v. Teleflex, 82 USPQ2d 1385, 127 S. Ct. 1727 (2007). Accordingly, it would have been obvious to use the wound structure of Phillips and the can bottom contact in the cell of Seefeldt et al. Regarding claim 10, it further would have been obvious to weld the current collector to the bottom of the can so as to ensure adequate electrical contact therewith. Accordingly, claim 10 would also be rendered obvious. Claims 13 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Seefeldt et al as applied to claims 1-7, 11 and 12 above, and further in view of Capati et al US 20190081309). Seefeldt et al. does not expressly teach at least two energy storage cells and at least one metallic conductor, the conductor connected by welding to the radially inwardly bent opening edges of both of the cells as recited in claims 13 and 14. Capati et al. is directed to a battery array with an integrated current collector. The integrated collector comprises a “second collector” (215) that is welded to the rims (that is, radially inwardly bent edges) of the cells to make a negative terminal connection ([0052], Fig. 2). A “first collector” (205) is connected to all the positive terminals. Therefore, the invention as a whole would have been obvious to one skilled in the art at the time of filing because all the claimed elements were known in the prior art and one skilled in the art could have combined the elements as claimed by known methods with no change in their respective functions and the combination would have yielded predictable results to one of ordinary skill in the art at the time of the invention. KSR v. Teleflex, 82 USPQ2d 1385, 127 S. Ct. 1727 (2007). Accordingly, it would have been obvious to use the collector structure of Capati et al. to make a battery array using the battery of Seefeldt et al. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Jonathan Crepeau whose telephone number is (571) 272-1299. The examiner can normally be reached Monday-Friday from 9:30 AM - 6:00 PM EST. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Nicole Buie-Hatcher, can be reached at (571) 270-3879. The phone number for the organization where this application or proceeding is assigned is (571) 272-1700. Documents may be faxed to the central fax server at (571) 273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). /Jonathan Crepeau/ Primary Examiner, Art Unit 1725 September 17, 2026
Read full office action

Prosecution Timeline

May 22, 2024
Application Filed
Sep 21, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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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
73%
Grant Probability
91%
With Interview (+18.0%)
3y 1m (~9m remaining)
Median Time to Grant
Low
PTA Risk
Based on 939 resolved cases by this examiner. Grant probability derived from career allowance rate.

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