Prosecution Insights
Last updated: October 02, 2026
Application No. 18/732,943

BATTERY

Non-Final OA §103§112
Filed
Jun 04, 2024
Priority
Jun 07, 2023 — JP 2023-094425
Examiner
HAMMOND, KRISHNA R
Art Unit
Tech Center
Assignee
Toyota Motor Corporation
OA Round
1 (Non-Final)
62%
Grant Probability
Moderate
1-2
OA Rounds
1y 7m
Est. Remaining
77%
With Interview

Examiner Intelligence

Grants 62% of resolved cases
62%
Career Allowance Rate
49 granted / 79 resolved
+2.0% vs TC avg
Moderate +15% lift
Without
With
+14.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 11m
Avg Prosecution
35 currently pending
Career history
128
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
77.5%
+37.5% vs TC avg
§102
10.7%
-29.3% vs TC avg
§112
11.3%
-28.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 79 resolved cases

Office Action

§103 §112
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 § 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. Claim 3 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for a lack of antecedent basis. Claim 1, upon which Claim 3 depends, recites “a cross-sectional area [a], in a cross-section orthogonal to the direction in which the injection port-side surfaces extend, of regions of the uncoated regions that face the injection port-side surfaces is larger than a cross-sectional area [d] of the channels in a cross-section orthogonal to the direction in which the channels extend.” If shortened to focus upon the first element of this clause, this concerns, “a cross sectional area [a] . . . . of regions of the uncoated regions that face the injection port-side surfaces.” Claim 3 recites “the cross-sectional area [a] of the uncoated regions.” This lacks antecedent basis because the difference in scope between these two terms. “Regions of the uncoated region” represents an arbitrary “slice” of the overall cross sectional area of a selected region of the uncoated regions. By contrast “the cross-sectional area [a] of the uncoated regions” more straightforwardly implicates the cross section of the uncoated regions (which face the injection port-side surfaces and are orthogonal to the direction in which they extend) in its entirety. 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 1-5 are rejected under 35 U.S.C. 103 as being unpatentable over Kamiya et. al. (JP2018156834A), in view of Kim, et. al. (EP4002512A1). Regarding Claim 1, Kamiya teaches a battery comprising: an electrode stack comprising a stack of electrodes (“[0024] As shown in FIG. 2, the power storage module 12 includes a stacked body 30 in which a plurality of bipolar electrodes 32 are stacked”), each including a current collector (electrode plate 34) and an active material layer (positive electrode active material layer 36, negative active material layer 38) that is provided on one or both surfaces of the current collector. Kamiya at [0024], Fig. 1-2. Kamiya further discloses the electrical conductor 14, which has a series of coolant channels, shown in Fig. 1, and contacts the entirety of the module 12, shown comprising the positive and negative electrodes 34, 36. Kamiya at Fig. 1-2. Further, Kamiya teaches the edge portion 34a of the electrode plate also contacts the frame body 50 of each module, each frame body comprising a first resin portion 52, and a plurality of first liquid injection ports. Id. at [0033]. Finally, Kamiya teaches an internal space V that is “airtightly partitioned by the electrode plates 34, 236, and the first resin portion 52 of the frame body 50,” contains the electrolyte. Id. at [0027], Fig. 2. PNG media_image1.png 420 544 media_image1.png Greyscale Fig. 1-2 of Kamiya. Note the internal space V, which contains the electrolyte. PNG media_image2.png 295 406 media_image2.png Greyscale Fig. 3 and 4 of Kamiya. Regarding “a sealing body that forms internal spaces [i.e., the volumes V] holding an electrolyte solution between the current collectors that are adjacent and seals the internal spaces, and injection ports that are formed in the sealing body [resin portion 52] and communicate the internal spaces with the outside [while the ports are sealed, these “communicate with the outside” when interfacing with the liquid injection jig 60”], wherein the internal spaces are formed by the channels and uncoated regions around the active material layers where the active material layers are not provided [uncoated edge portions 34a], internal regions sealed by the sealing body have a polygonal shape [see Fig. 2; a polygonal shape is made up of line segments which form a closed chain, including the U-shaped cross sectional view of V] when viewed from a stacking direction of the electrode stack [if rotated, these form a U-shaped prism], and when surfaces, on the internal space side, of the side of the sealing body where the injection ports are formed are called injection port-side surfaces [i.e., the portion of the resin portion 52 having the plurality of first injection ports 52 a],” this is disclosed by Fig. 2 of Kamiya because “[0029] The edge portion 34 a of the electrode plate 34 is an uncoated area to which the positive electrode active material and the negative electrode active material are not applied and the uncoated area is buried in the first resin portion 52.” Id. at [0029], Fig. 2. Regarding “and a cross-sectional area [a], in a cross-section orthogonal to the direction in which the injection port-side surfaces extend, of regions of the uncoated regions that face the injection port-side surfaces is larger than a cross-sectional area [d] of the channels in a cross-section orthogonal to the direction in which the channels extend,” the Office notes that as understood, the injection port communicates with the internal space V ([0033]), placing the port directly facing the x direction. The uncoated portion “orthogonal” to this direction is understood to be the top of the “U” shape formed by the volume V, shown in Fig. Further, the uncoated portion is partially covered by the resin portion 52, but is understood to extend until the portion overlapping the separator 40 (i.e., so that the coated portion is not vulnerable to short circuit). This uncoated portion, due to its xy directional length and width as shown in Fig. 2 (including the portion extending into the page) , is larger than that of a cross section orthogonal to the direction the channels extend (because the extending direction is in the xy, this is the cross sectional surface xz, i.e., the portion of the resin portion 52 in the xz direction). Consequently, Kamiya teaches “and a cross-sectional area [a], in a cross-section orthogonal to the direction in which the injection port-side surfaces extend, of regions of the uncoated regions that face the injection port-side surfaces is larger than a cross-sectional area [d] of the channels in a cross-section orthogonal to the direction in which the channels extend.” However, regarding “electrodes . . . divided into plural regions with channels in between,” these channels are interpreted as an electrode being divided into plural regions with channels in between (i.e., instead of the stack being divided into modules). Consequently, Kamiya is silent as to “electrodes . . . divided into plural regions . . . . [wherein] the channels extend between the divided regions of the active material layers from the side where the injection port-side surfaces are in the opposite direction of the injection port-side surfaces.” Kim teaches a secondary battery, having positive electrode plates 100, wherein “[0059] As described above, the plurality of positive electrode plates 100 may be disposed on and extend from the upper surface of the base layer 110 and are spaced apart from each other at a predetermined interval, so that a channel C may be present between adjacent positive electrode plates amongst the plurality of positive electrode plates 100. As shown in FIG. 2B , the positive electrode may include a plurality of channels C between the plurality of positive electrode plates 100. The width and shape of the channel C is defined by surfaces of adjacent positive electrode plates. Herein, the channel C may have a constant width corresponding to the distance of the interval between the plurality of positive electrode plates 100. The channel C may extend to a predetermined depth in the base layer 110 between the plurality of positive electrode plates 100. The depth of the channel C may be variously modified. [0060] The channel C formed between the plurality of positive electrode plates 100 may be filled with the electrolyte material 30 of the secondary battery. According to an embodiment, the electrolyte material may be disposed in the channel between the plurality of positive electrode plates. For example, the electrolyte material 30 may be a liquid electrolyte, and thus, the channel C and pores in the base layer 110 connected to the channel C may be filled with the electrolyte.” Kim at [0059, 60], Fig. 2B. Kim teaches that this is beneficial because “[0061] In addition, by forming a positive electrode having the three-dimensional structure in which the plurality of positive electrode plates 100 are disposed spaced apart from each other on the surface of the base layer 110, and by placing the electrolyte material 30 having high ionic conductivity in the channel C, the ionic conductivity of the positive electrode may be increased. When the ion conductivity is increased, the height of the plurality of positive electrode plates 100 may also be increased, so that the current density may be increased.” PNG media_image3.png 370 402 media_image3.png Greyscale Fig. 2B of Kim. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to modify the battery of Kamiya, such that it comprises the positive electrodes plates divided into plural regions with channels in between as in Kim (see the branch structure of the plates 100), as well as substantially quadrilateral channels C such that modified Kamiya comprises “electrodes . . . divided into plural regions . . . . [wherein] the channels extend between the divided regions of the active material layers from the side where the injection port-side surfaces are in the opposite direction of the injection port-side surfaces,” while maintaining the prior cross-sectional [a] and [d] relationship, because Kim teaches a benefit to ionic conductivity. Claim 1 is obvious over Kamiya, in view of Kim. Regarding Claim 2, Claim 2 relies upon Claim 1. Claim 1 is obvious over modified Kamiya. Kamiya discloses the plurality of injection ports 52a are upon one side of the first resin portion 52, shown in Fig. 2. Kamiya at Fig. 2, [0033]. Further, as modified by Kim, modified Kamiya comprises quadrilateral channels. Kim at Fig. 2B. Consequently, modified Kim teaches “the internal regions sealed by the sealing body have a quadrilateral shape when viewed from the stacking direction of the electrode stack, and the battery has the injection ports only in a region of the sealing body that faces one side of the quadrilateral shape.” Claim 2 is obvious over Kamiya, in view of Kim. Regarding Claim 3, Claim 3 relies upon Claim 1. Claim 1 is obvious over modified Kamiya. The previous 112 rejection notwithstanding, modified Kim is silent as to the ratio ([d]/[a]) of the cross-sectional area [d] of the channels to the cross-sectional area [a] of the uncoated regions is 0.1 to 0.9, because the relative areas and lengths are not disclosed in Kamiya. However, Kim teaches “[0058] the width W and height H of the positive electrode plate 100 may be variously modified to provide an aspect ratio greater than 1. The plurality of positive electrode plates 100 may each have the same length L. However, the present disclosure is not limited thereto, and at least one positive electrode plate of the plurality of positive electrode plates 100 may have a different length,” and “[0061] When the ion conductivity is increased, the height of the plurality of positive electrode plates 100 may also be increased, so that the current density may be increased.” In other words, the overall height of the electrode plates, and thereby the uncoated regions, are a result effective variable which modifies current density. Further, this presents an inference that, because Kim teaches the purpose of the channel C is to improve ionic conductivity, that the dimensions of the channel when compared to the uncoated portions would be obvious to modify to balance current density while optimizing ionic conductivity (via additional flow of electrolyte). Id. One of ordinary skill in the art before the effective filing date would find it obvious to further modify the battery of modified Kamiya, such that the wherein the ratio ([d]/[a]) of the cross-sectional area [d] of the channels to the cross-sectional area [a] of the uncoated regions is 0.1 to 0.9, because the cross sectional area of the uncoated portions, as well as the dimensions of the Channel C, are result effective variables, indicating that one of ordinary skill in the art before the effective filing date would arrive at the claim terms through routine optimization. MPEP 2144.05 (II). Claim 3 is obvious over Kamiya, in view of Kim. Regarding Claim 4, Claim 4 relies upon Claim 1. Claim 1 is obvious over modified Kamiya. Modified Kamiya is silent as to the area of the electrode stack. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to further modify the battery of Kamiya, such that the cross-sectional area [d] of the channels is 0.4 mm2 to 2.0 mm2, because where the only difference between the prior art and the claims is a recitation of relative dimensions of the claimed device and a device having the claimed relative dimensions would not perform differently than the prior art device, the claimed device is not patentably distinct from the prior art device. MPEP 2144.04 (IV)(A). Claim 4 is obvious over Kamiya, in view of Kim. Regarding Claim 5, Claim 5 relies upon Claim 1. Claim 1 is obvious over modified Kamiya. Modified Kamiya is silent as to the area of the electrode stack. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to further modify the battery of Kamiya, such that the area of the electrode stack when viewed from the stacking direction of the electrode stack is 0.5 m2 or more, because where the only difference between the prior art and the claims is a recitation of relative dimensions of the claimed device and a device having the claimed relative dimensions would not perform differently than the prior art device, the claimed device is not patentably distinct from the prior art device. MPEP 2144.04 (IV)(A). Claim 5 is obvious over Kamiya, in view of Kim. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to KRISHNA RAJAN HAMMOND whose telephone number is (571)272-9997. The examiner can normally be reached 9:00 - 6:30 PM 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, Nicole Buie-Hatcher can be reached at (571) 270-3879. 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. /K.R.H./ Examiner , Art Unit 1725 /NICOLE M. BUIE-HATCHER/ Supervisory Patent Examiner, Art Unit 1725
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Prosecution Timeline

Jun 04, 2024
Application Filed
Sep 08, 2026
Non-Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
62%
Grant Probability
77%
With Interview (+14.9%)
3y 11m (~1y 7m remaining)
Median Time to Grant
Low
PTA Risk
Based on 79 resolved cases by this examiner. Grant probability derived from career allowance rate.

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