DETAILED ACTION
(1)
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 . Applicant’s response filed April 23, 2026, is entered. Applicant amended claims 1, 3 and 13 and cancelled claims 2 and 14. No new matter is entered. Claims 1 and 3-12 remain pending before the Office for review. Claims 13 and 15-28 remain withdrawn in response to a restriction requirement.
(2)
Claim Rejections - 35 USC § 103
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claims 1, 3, 5-8, 10 and 11 are rejected under 35 U.S.C. 103 as being unpatentable over Morad et al., (U.S. Publication No. 2017/0077343) in view of Naoki et al., (EP 2 012 364 A1), which is cited in Applicant’s information disclosure statement.
With respect to claim 1, Morad teaches a method for cross-connecting a solar cell array (Figures 1, 5A and 11A) made of crystalline solar cells (10; paragraphs 221 and 222) comprising using at least one cross-connector (flexible interconnect described in paragraph 269) that is electrically conductive for cross-connecting the solar cell array. Figures 1, 5A and 11A and Paragraphs 221, 222, 266, 269 and 318. Morad specifically teaches the cells in each row are connected in parallel to the cell of a neighboring row and the two groups of cells are connected in series. Paragraph 318.
Morad teaches an electrically conductive adhesive tape connects the cells within a row. Paragraph 223. Morad also teaches the cross-connecting between adjacent rows of the array is affected with a flexible interconnect that extends from the top of one cell to the bottom of the adjacent cell (paragraphs 266 and 269), but is silent as to whether an electrically conductive adhesive tape is used in place of the flexible interconnect.
However, Naoki, which deals with solar cell modules, teaches a conductive adhesive tape is used to electrically interconnect solar cells (101) within a module, wherein the connection member (120) is an adhesive tape that covers the front surface of a first cell and extends to the rear surface of the adjacent cell. Figure 3 and Paragraphs 52-56. Naoki teaches using a conductive adhesive tape to affect this type of electrical interconnection is beneficial because the connection can be made at temperatures lower than solder, which prevents against cracking and warping of the solar cell and leads to an enhancement in yield of the solar modules from the method. Paragraph 12.
Therefore, it would have been obvious to one ordinarily skilled in the art at a time before the effective filing date of the claimed invention to utilize a conductive adhesive tape to affect the electrical interconnection of solar cells in the adjacent rows taught by Morad because Naoki teaches this connection mechanism is effective for connecting the top of a first solar cell to the rear of an adjacent solar cell and is associated with enhanced production yield, meaning the modification has a reasonable expectation of success.
To summarize, modified Morad teaches the method comprising bonding via adhesive the at least one cross-connector made of the electrically conductive adhesive tape, as taught by Naoki, to a row of the solar cells. Morad, Figures 5A and 11A and Paragraphs 266 and 269 and Naoki, Figure 3 and Paragraphs 52-56.
With respect to claim 3, modified Morad teaches the at least one cross-connector made of the electrically conductive adhesive tape is bonded to the sunny side (front surface) of the row and to a rear side of the row facing away from the sunny side. Morad, Figures 5A and 11A and Paragraphs 266 and 269 and Naoki, Figure 3 and Paragraphs 52-56.
With respect to claim 5, modified Morad teaches the solar array comprises at least two rows with a cross-connector extending between corresponding solar cells in each row, meaning the method comprises two or more cross-connectors made of electrically conductive adhesive tape bonded to different rows of the solar cells. Morad, Figures 5A and 11A and Paragraphs 266 and 269 and Naoki, Figure 3 and Paragraphs 52-56.
With respect to claim 6, modified Morad teaches the cross-connector is made of an electrically conductive adhesive that is bonded to the row of solar cells in the array. Morad, Figures 1, 5A and 11A and Paragraphs 221, 222, 266, 269 and 318 and Naoki, Figure 3 and Paragraphs 52-56. Modified Morad further teaches cover elements in the form of encapsulants (4101 and extra strip) are placed over gaps between adjacent cells of a row and applied to the rear side of the array that faces away from a sunny side of the array. Morad, Figure 8A and Paragraph 298.
Regarding whether cover elements are placed prior to bonding the cross-connector made of the electrically conductive adhesive tape to the row, as per the MPEP, the selection of any order of performing process steps is prima facie obvious in the absence of new or unexpected results. MPEP 2144.04(IV)(C) (internal citation omitted). In this case, whether the cover is placed before or after the cross-connector is connected thereto, the method obtains an encapsulated solar cell module within the scope of the claimed invention.
With respect to claim 7, modified Morad teaches the method further comprises electrically connecting one of the cross-connectors for connection to a junction box via a longitudinal connector (455) that extends from the array to the junction box. Figure 9A and Paragraph 299.
With respect to claim 8, modified Morad teaches a conductive adhesive tape is an effective electrical interconnector within a solar cell module because it allows for lower processing temperatures, which leads to enhanced yield. Naoki, Paragraph 12. It would have been obvious to one ordinarily skilled in the art at a time before the effective filing date of the claimed invention to utilize conductive adhesive tape as the longitudinal connector for this reason – enhancing the yield while allowing for lower temperature processing. Naoki teaches the electrically conductive adhesive is an effective interconnect component in solar modules, meaning using the adhesive tape to electrically interconnect the solar cell to a junction box has a reasonable expectation of success.
With respect to claim 10, modified Morad teaches the solar array is interconnected to a junction box via a longitudinal connector (455) that extends at right angles to a row orientation of the solar cell array over the rows of the solar cells. Figure 9A and Paragraph 299.
With respect to claim 11, modified Morad teaches an electrical insulator in the form of an encapsulant is placed to cover the cells in the row of solar cells, which encompasses covering the row at right angles to a row orientation of the cells on the rows, among other directions, wherein the encapsulant is placed between two of the cross-connectors and the longitudinal connector (455) associated with the junction box is placed on the encapsulant. Figures 8A and 9A and Paragraphs 298 and 299.
(3)
Claims 4 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Morad et al., (U.S. Publication No. 2017/0077343) in view of Naoki et al., (EP 2 012 364 A1), as applied to claims 1, 3, 5-8, 10 and 11 above, and further in view of He et al., (U.S. Publication No. 2013/0206213).
With respect to claims 4 and 12, modified Morad teaches the cross-connector is made of electrically conductive adhesive tape (Naoki, Paragraphs 52-56), but is silent as to whether it is bonded as an initial cross-connector onto a support structure for the solar cell array prior to placing the solar cell array thereon and bonding the cross-connector to the solar cell array.
However, He, which deals with shingled solar cells on a support structure, teaches the solar cell array shingled matrix structure is obtained by bonding a bus bar (330), which is a type of cross-connector, to a support structure (388) and then shingling the solar cells thereon in a matrix array. Figure 1D and Paragraphs 15 and 23.
It would have been obvious to one ordinarily skilled in the art at a time before the effective filing date of the claimed invention the combination of modified Morad with He is the use of a known technique to improve a similar array in the same way. Both modified Morad and He are directed toward shingled solar cell arrays that are interconnected in series and/or parallel. He teaches the shingling matrix of the array can be obtained by placing the electrically adhesive conductor on a support substrate followed by layering of the shingle matrix thereon. It would have been obvious to one ordinarily skilled in the art at a time before the effective filing date of the claimed invention to similarly structure Morad’s array with this method utilizing the electrically conductive adhesive tape on the support structure because He teaches this technique to be effective for affecting a shingled matrix, meaning the modification has a reasonable expectation of success.
Regarding whether a solar cell array is placed onto the initial cross-connector of the support structure or if the array is shingled thereon, as per the MPEP, the selection of any order of performing process steps is prima facie obvious in the absence of new or unexpected results. MPEP 2144.04(IV)(C) (internal citation omitted). In this case, whether the shingled matrix is applied thereto and shingled thereon, the method obtains a shingled matrix array on the support structure with initial cross-connector.
(4)
Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Morad et al., (U.S. Publication No. 2017/0077343) in view of Naoki et al., (EP 2 012 364 A1), as applied to claims 1, 3, 5-8, 10 and 11 above, and further in view of Hiroshi et al. (EP 2 426 735 A1).
With respect to claim 9, modified Morad teaches the cross-connector is bonded to a row of cells of the array. Morad, Morad, Figures 5A and 11A and Paragraphs 266 and 269 and Naoki, Figure 3 and Paragraphs 52-56.
Modified Morad is silent as to whether the cross-connector comprises an overhang over a row end of a row of the cells.
However, Hiroshi, which deals with arrayed solar cells in a module, teaches the electrically conductive adhesive tape (1) that facilitates electrical interconnection of adjacent cells comprises an overhang extending over a row end of the solar cells. Figures 5 and 19 and Paragraphs 82 and 83. Hiroshi teaches, as seen in figure 5, the overhang facilitates connection to an adjacent junction box. Figure 5.
Therefore, it would have been obvious to one ordinarily skilled in the art at a time before the effective filing date of the claimed invention to place the cross-connector to comprise an overhand over a row end of the cells because Hiroshi teaches doing so facilitates connection to an adjacent junction box.
(5)
Response to Arguments
Applicant’s arguments, filed April 23, 2026, are not persuasive. Applicant first argues Morad teaches a combination of an electrically conductive adhesive tape in conjunction with an electrical conductor in the form of a ribbon and does not teach “the exclusive use of an electrically conductive adhesive tape as a cross-connector….” Applicant’s argument is not persuasive because it misstates the scope of the claimed invention. There is no exclusivity requirement in the claimed invention. Additionally, Morad and Naoki, in combination, teach the use of an electrically conductive adhesive tape as a cross-connector. In response to Applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
Applicant next argues Naoki teaches an adhesive tape that is a foil with an adhesive layer and not the “’scotch-tape-like tape’” described in the present application. Applicant’s argument is not persuasive because it is not a feature of the claimed invention. The broadest reasonable interpretation of the “electrically conductive adhesive tape” covers the tape taught by Naoki.
Applicant argues Naoki discloses serial connections and not the cross-connection requirement of the claimed invention. Again, as noted above, Morad teaches this feature of the claimed invention. In response to Applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
Applicant next argues the “electrical, mechanical and thermal requirements differ significantly between the two approaches” and there would not be a reasonable expectation of success for the combination of Morad and Naoki. Applicant’s argument is not persuasive because it is an unsupported assertion. Examiner reviewed the specification and cannot find any disclosure of these specific requirements in the context of the inventive adhesive tape. Additionally, Applicant’s argument raises the possibility that the claimed invention is not enabled or not enabled for its full scope.
Applicant’s argument regarding Hiroshi is also not persuasive because it relies on unclaimed features. There is no requirement in the claimed invention for applying the tape directly to the solar cells. As such, Hiroshi’s teachings, in combination with Morad and Naoki, as explained above, are within the scope of the claimed invention.
(6)
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ELI S MEKHLIN whose telephone number is (571)270-7597. The examiner can normally be reached Monday-Friday 7:00 am to 5:00 pm EST.
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/ELI S MEKHLIN/Primary Examiner, Art Unit 1759
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