Prosecution Insights
Last updated: October 27, 2026
Application No. 18/801,245

BATTERY MODULE

Non-Final OA §102§103§112
Filed
Aug 12, 2024
Priority
Jan 26, 2024 — RE 10-2024-0012236
Examiner
EFYMOW, JESSE JAMES
Art Unit
Tech Center
Assignee
Samsung SDI Co., Ltd.
OA Round
1 (Non-Final)
79%
Grant Probability
Favorable
1-2
OA Rounds
1y 3m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allowance Rate
22 granted / 28 resolved
+18.6% vs TC avg
Strong +54% interview lift
Without
With
+54.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
34 currently pending
Career history
88
Total Applications
across all art units

Statute-Specific Performance

§103
59.4%
+19.4% vs TC avg
§102
24.3%
-15.7% vs TC avg
§112
13.5%
-26.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 28 resolved cases

Office Action

§102 §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 . Summary This is a non-final office action for application 18/801,245 filed on 08/12/2024. Claims 1-18 are pending. Priority Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). The certified copy has been filed in parent Application No. KR10-2024-0012236 filed on 01/26/2024. Information Disclosure Statement The information disclosure statements (IDS)s submitted on 08/12/2024 and 04/18/2025 are being considered by the examiner. Drawings The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they include the following reference character(s) not mentioned in the description. Part number A and A’ in FIG. 2B Part number I’ in FIG. 4 Part number h’ in FIG. 5A Part number I’ in FIG. 5B Corrected drawing sheets in compliance with 37 CFR 1.121(d), or amendment to the specification to add the reference character(s) in the description in compliance with 37 CFR 1.121(b) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Objections Claim 13 is objected to because of the following informalities: Claim 13 recites the limitation "at an approximately middle of the pouch region” however, should recite “at approximately a middle of the pouch region” for the sake of proper grammar. 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. Claim 12 is 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 12, claim 12 recites the limitation “the volume increasing sequentially from an upper part of the pouch region.” However it is unclear what sequence of volume increase is required, including the direction in which the increase proceeds and which portions of the pouch region must increase in volume in succession. While paragraphs [0060]-[0061] of the instant specification do describe expansion occurring mainly in an upper part or in upper and lower parts of the pouch region, the specification does not define or explain a sequential volume increase. Claim Rejections - 35 USC § 102 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 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 1-3, 5-9, 11, 13-14 and 16-17 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Eaves et al. (US-20100028758-A1 cited in IDS). Regarding Claim 1, Eaves discloses a battery module (see e.g. "a battery pack" in paragraph [0030] and FIG. 2) comprising: a plurality of battery cells arranged in one direction (see e.g. "six individual cylindrical battery cells 10" in paragraph [0030] and part number 10 in FIG. 2); and at least one insulating spacer between the plurality of battery cells (see e.g. "thermal suppression element 1 between the cells of the groups, such that the suppression element is in good thermal contact with each of the cells 10, whereby it can effectively absorb and safely dissipate a substantial portion of any heat released from the cells" in paragraph [0030] and part number 1 in FIG. 2), wherein the insulating spacer comprises: a pouch region having a space defined therein (see e.g. "a thermal suppression element 1 comprising a liquid-tight pouch" in paragraph [0029] and paragraph [0033]); and a phase change material configured to fill at least a portion of the space (see e.g. "Before all seams are closed the pouch is filled with a hydrated hydrogel-forming polymer (hydrogel)" in paragraph [0029] and "In the event a cell overheats, the water retained in the gel is heated and may be fully or partially vaporized, absorbing the thermal energy released by the cell, and preventing thermal runaway" in paragraph [0021]). Regarding Claim 2, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves further discloses that the phase change material is in a liquid state in response to a temperature of the phase change material being less than a predetermined temperature (see e.g. "Absorption of heat by the process of change of phase of a material, in this case change of phase of water from liquid to gaseous phase, can be referred to as phase change material (PCM) energy absorption." in paragraph [0028] and "according to the invention the water comprised by the hydrogel must be heated from ambient temperature, typically 20° C., to its boiling point of 100° C. before phase change, i.e., vaporization, takes place" in paragraph [0038]). Regarding Claim 3, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves further discloses that the phase change material is configured to vaporize from a liquid state to a gas state in the space of the pouch region in response to a temperature of the phase change material being equal to or higher than a predetermined temperature (see e.g. " If heated sufficiently, the water will at least partially vaporize, thus absorbing an amount of heat per molecule vaporized equal to the latent heat of vaporization" in paragraph [0028] and "according to the invention the water comprised by the hydrogel must be heated from ambient temperature, typically 20° C., to its boiling point of 100° C. before phase change, i.e., vaporization, takes place" in paragraph [0038] and paragraph [0040]). Regarding Claim 5, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves further discloses that the pouch region of the insulating spacer comprises a front sheet coupled to a rear sheet, and wherein an edge of the pouch region is bonded (see e.g. paragraph [0034]). The two opposed sheets respectively correspond to the claimed front sheet and rear sheet, and sealing the sheets together along their four sides constitutes bonding an edge of the pouch region. Regarding Claim 6, Eaves discloses the battery module of claim 5 (see e.g. claim 5 rejection above). Eaves further discloses that the pouch region comprises polyethylene or polypropylene (see e.g. "A preferred film material is well-known in the art as FR2175-B; this is available from a variety of vendors, and is described (using terminology common in the art) as comprising successive layers of 90 gauge oriented polypropylene, 15 pound polyethylene, 0.000285″ aluminum foil, and 40 pound low density polyethylene film. " in paragraph [0042]). Regarding Claim 7, Eaves discloses the battery module of claim 5 (see e.g. claim 5 rejection above). Eaves further discloses that a shape of the pouch region is configured to vary in response to a pressure in the pouch region (see e.g. "the gel of the thermal suppression element in the pouch conforms to the shape of the cells" in paragraph [0021] and "The final package is liquid-tight and flexible such that it may conform to the voids at the interface between cell groups." in paragraph [0029] and paragraph [0031]). Eaves also discloses that during testing the pouch “bulged somewhat” as water within the pouch partially vaporized (see e.g. paragraph [0040]). The vaporization of the water generates gas within the sealed pouch and consequently increases the internal pressure, causing the flexible pouch to bulge and change shape. Regarding Claim 8, Eaves discloses the battery module of claim 5 (see e.g. claim 5 rejection above). Eaves further discloses that the front sheet and the rear sheet of the pouch region are in contact with battery cells of the plurality of battery cells adjacent to the front sheet and the rear sheet (see e.g. "the cell groups are assembled so as to confine the thermal suppression element 1 between the cells of the groups, such that the suppression element is in good thermal contact with each of the cells 10," in paragraph [0030] and FIGs. 2 and 4). Regarding Claim 9, Eaves discloses the battery module of claim 5 (see e.g. claim 5 rejection above). Eaves further discloses that the phase change material comprises a material having a boiling point from approximately 20° C. to approximately 100° C (see e.g. "according to the invention the water comprised by the hydrogel must be heated from ambient temperature, typically 20° C., to its boiling point of 100° C. before phase change, i.e., vaporization, takes place" in paragraph [0038]). Eaves discloses a range that overlaps with the range claimed in the instant application. Eaves, however, discloses a phase change material that has no difference to the phase change material that is claimed in the instant application. In the case where the prior art discloses a range that overlaps with the claimed range and sufficient specificity is shown then the prior art anticipates the claimed range. See MPEP 2131.03 (II). Regarding Claim 11, Eaves discloses the battery module of claim 5 (see e.g. claim 5 rejection above). Eaves further discloses that the pouch region seals the phase change material by bonding (see e.g. "a flat sheet of material is first folded to form a closed edge 20, and the opposed juxtaposed edges are heat sealed at 22. The pouch 26 is then filled with the preferred hydrogel material, and the fourth side sealed at 24." in paragraph [0033]). Regarding Claim 13, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves further discloses that the insulating spacer comprises a front sheet, a rear sheet, and an adhesion region bonding the front sheet to the rear sheet at an approximately middle of the pouch region (see e.g. "a sheet of material is first folded at the sides 3 and opposed edges are then heat-bonded to one another to form a longitudinal seam 4." in paragraph [0032] and FIG. 1; the folded sheet with two opposed sheets respectively correspond to the claimed front sheet and rear sheet, the longitudinal seam 4 corresponds to an adhesion region bonding the front sheer to the rear sheet a an approximate middle of the pouch). Regarding Claim 14, Regarding Claim 16, Eaves discloses the battery module of claim 14 (see e.g. claim 14 rejection above). Eaves further discloses that the adhesion region is configured to maintain adhesion between the front sheet and the rear sheet even in response to a volume of the pouch region being increased (see e.g. “the pouch of the TSE bulged somewhat, indicating partial vaporization” and “the pouch retained its structural integrity and did not leak” in paragraph [0040]). Regarding Claim 17, Eaves discloses the battery module of claim 5 (see e.g. claim 5 rejection above). Eaves further discloses that the insulating spacer further comprises a border region along an edge of the pouch region (see e.g. "sealing of two separate sheets of film material to one another along four sides" in paragraph [0034] and "sealing of two separate sheets of film material to one another along four sides" in paragraph [0033] and part number 24 in FIG. 3). 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 12 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Eaves et al. (US-20100028758-A1). Rgearding Claim 12, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves further discloses that vaporization of the phase change material increases the volume of the pouch region (see e.g. “the pouch of the TSE bulged somewhat, indicating partial vaporization” in paragraph [0040]). Eaves does not explicitly disclose that the volume increases sequentially from an upper part of the pouch region. However, it would have be obvious to a person of ordinary skill in the art that the volume of the pouch of Eaves would increase sequentially from an upper part of the pouch region due to the vaporized phase change material predictably migrating toward and accumulating within the upper space of the flexible pouch causing expansion and thus an increase in volume in the upper part as vaporization continues. Regarding Claim 15, Eaves discloses the battery module of claim 14 (see e.g. claim 14 rejection above). Eaves further discloses a longitudinal adhesion seam intersecting an opposed end adhesion seams at multiple bonding locations (see e.g. “heat-seal seams are placed in optimum positions” in paragraph [0029] and “opposed edges are then heat-bonded to one another to form a longitudinal seam 4” in paragraph [0032] and part numbers 4 and 5 in FIG. 1). Eaves does not explicitly disclose that the adhesion region comprises a plurality of adhesion regions arranged in at least one row. However, it would be obvious to a person of ordinary skill in the art that the aligned bonding locations formed along longitudinal seam 4 intersection with end adhesion seam 5 are a plurality of adhesion regions arranged in at least one row used to distribute the bonding forces between sheets and maintain adhesion during the expansion of the pouch. Claims 4 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Eaves et al. (US-20100028758-A1) as applied to claims 1 and 17 above, and further in view of Yoon (US-20210320345-A1 cited in IDS). Regarding Claim 4, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves does not disclose that the phase change material fills a half or less of the space. Yoon, however, in the same field of endeavor, battery modules with phase change material in an insulation sheet, discloses an insulation sheet containing a phase change material and evaluates insulation sheets in which the phase change material occupies 30% and 50% of the insulation sheet (see e.g. Table 1 and paragraphs [0058]-[0059] of Yoon). Yoon discloses points that lie within the range claimed by the instant application. In the case where the prior art discloses a point within the claimed range, a prima facie case of obviousness exists. See MPEP 2144.05 (I). Yoon also teaches that phase change material loadings of 30% and 50% provide reduced thermal conductivity relative to a hole free insulation sheet while retaining phase change material for absorbing heat (see e.g. paragraphs [0058]-[0061] of Yoon). Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the phase change material of Eaves et al. such that the phase change material fills a half or less of the space as taught by Yoon et al. in order to reduce thermal conductivity while retaining phase change material for absorbing heat as suggested by Yoon. Regarding Claim 18, Eaves discloses the battery module of claim 17 (see e.g. claim 17 rejection above). Eaves does not disclose that the border region comprises mica. Yoon, however, discloses a heat-insulating sheet that comprises mica (see e.g. "The heat-insulating sheet may be made of ceramic or mica" in paragraph [0014] of Yoon). Yoon also teaches that by including mica in the heat-insulating sheet reduces thermal conductivity thereby preventing or reducing heat transfer between battery cells, and delaying, preventing, and/or reducing the event that may be caused by the heat (see e.g. paragraph [0061] of Yoon). Therefore, it would have been obvious to a person of ordinary skill in the art, before the effective filling date of the claimed invention, to modify the insulating spacer of Eaves et al. such that the border region of the insulating spacer comprises mica as taught by Yoon in order to further reduce thermal conductivity and prevent or reduce heat transfer between battery cells as suggested by Yoon. Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Eaves et al. (US-20100028758-A1) as applied to claim 1 above, and further in view of Park et al. (US-20220158277-A1). Regarding Claim 10, Eaves discloses the battery module of claim 1 (see e.g. claim 1 rejection above). Eaves does not disclose that the phase change material comprises methoxy-nonafluorobutane (C4F9OCH3). Park, however, in the same field of endeavor, thermal suppression of battery modules, discloses a phase change material (see e.g. "one battery module with a non-conductive dielectric fluid that undergoes a phase change during the contacting" in paragraph [0007] of Park) that comprises methoxy-nonafluorobutane (C4F9OCH3) (see e.g. ". In this example, the dielectric fluid is 3M Novec™ 7100" and "3M™ Novec™ 7100 Engineered Fluid, methoxy-nonafluorobutane (C4F9OCH3)" in paragraphs [0131]-[0132] of Park). Park also teaches that this fluid has a particularly advantageous cooling effect since both the heat capacity of the fluid and the fluid's heat of vaporization transfer heat away from the cell in a particularly efficient manner (see e.g. paragraph [0147] of Park). Therefore, it would have been obvious to a person of ordinary skill in the art, before the effective filing date of the claimed invention, to modify the phase change material of Eaves et al. such that it comprises methoxy-nonafluorobutane (C4F9OCH3) as taught by Park et al. in order to transfer heat away from the battery cells in a particularly efficient manner as suggested by Park. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Jeon (US-20200067152-A1) Choi (US-20170222283-A1) Any inquiry concerning this communication or earlier communications from the examiner should be directed to JESSE EFYMOW whose telephone number is (571)270-0795. The examiner can normally be reached Monday - Thursday 10:30 am - 8:30 pm EST. 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 (571) 270-7871. 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. /J.J.E./Examiner, Art Unit 1723 /NICHOLAS P D'ANIELLO/Primary Examiner, Art Unit 1723
Read full office action

Prosecution Timeline

Aug 12, 2024
Application Filed
Oct 07, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
79%
Grant Probability
99%
With Interview (+54.5%)
3y 6m (~1y 3m remaining)
Median Time to Grant
Low
PTA Risk
Based on 28 resolved cases by this examiner. Grant probability derived from career allowance rate.

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