Prosecution Insights
Last updated: October 02, 2026
Application No. 19/003,505

COMPOSITE STORAGE TANK FOR LIQUID HYDROGEN

Final Rejection §103
Filed
Dec 27, 2024
Priority
Dec 29, 2023 — provisional 63/616,105
Examiner
CASTRIOTTA, JENNIFER
Art Unit
3733
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
General Electric Company
OA Round
2 (Final)
62%
Grant Probability
Moderate
3-4
OA Rounds
9m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 62% of resolved cases
62%
Career Allowance Rate
438 granted / 704 resolved
-7.8% vs TC avg
Strong +29% interview lift
Without
With
+28.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
31 currently pending
Career history
746
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
42.8%
+2.8% vs TC avg
§102
22.1%
-17.9% vs TC avg
§112
30.3%
-9.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 704 resolved cases

Office Action

§103
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 § 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. Claim(s) 1, 5-8, and 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Thunhorst et al. (US 9822928) (hereinafter Thunhorst) in view of Blum et al. (US 5419319) (hereinafter Blum). Regarding Claim 1 Thunhorst teaches a composite storage tank (below – Fig. 3 and 4) for storing liquified gas (e.g. liquid hydrogen), the composite hydrogen storage tank comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including: an inner composite layer (230a) including a plurality of reinforcing fiber tows surrounded by a matrix, the inner composite layer including an inner surface defining the chamber; a hydrogen barrier layer (270) formed on the inner surface of the inner composite layer, the hydrogen barrier layer being a metal layer; an outer composite layer (230b) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix; and a plurality of insulating layers (not shown) between the inner composite layer and the outer composite layer (Col. 5, Ln. 22 – Col/ 6, Ln. 30). PNG media_image1.png 273 289 media_image1.png Greyscale PNG media_image2.png 194 405 media_image2.png Greyscale Thunhorst does not teach the metal layer having a thickness from five mils to fifty mils. Blum teaches a composite hydrogen storage tank (Fig. 1 and 3) for storing liquid hydrogen, the composite hydrogen storage tank (10) comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including; a hydrogen barrier layer (14) formed on an inner surface of the tank, the hydrogen barrier layer being a metal layer (16/20) capable of having a thickness from five mils to fifty mils; an outer composite layer (11) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix (Col. 5, Ln. 17 – Col. 6, Ln. 7; and Col. 6, Ln. 60 – Col. 7, Ln. 6). PNG media_image3.png 309 434 media_image3.png Greyscale PNG media_image4.png 202 329 media_image4.png Greyscale Thunhorst and Blum are analogous inventions in the field of hydrogen storage tanks. It would have been obvious to one skilled in the art at the time of filing to modify the hydrogen barrier layer of Thunhorst with the teachings of the metal hydrogen barrier layer capable of having a thickness from five mils to fifty mils of Blum in order to provide a hydrogen barrier layer that provides low gas permeability while reducing the weight of the overall tank (Col. 4, Ln. 60-64). Regarding Claim 5 Thunhorst in view of Blum (hereinafter “modified Thunhorst”) teaches all the limitations of claim 1 as shown above. Thunhorst further teaches the hydrogen barrier layer is an inner hydrogen barrier layer (270), and the composite hydrogen storage tank further comprises an intermediate hydrogen barrier layer positioned between the inner composite layer and the outer composite layer (Col. 5, Ln. 28-60 and Col. 6, Ln. 8-19). Regarding Claims 6 and 7 Modified Thunhorst teaches all the limitations of claim 1 as shown above. Thunhorst further teaches the plurality of insulating layers includes a plurality of low-conductivity layers including an inner low-conductivity layer and an outer low-conductivity layer; and wherein the hydrogen barrier layer is an inner hydrogen barrier layer, and the composite hydrogen storage tank further comprises an intermediate hydrogen barrier layer positioned between the inner low-conductivity layer and the outer low-conductivity layer (Col. 5, Ln. 28-60 and Col. 6, Ln. 8-19). Regarding Claim 8 Modified Thunhorst teaches all the limitations of claim 1 as shown above. Thunhorst further teaches one of the plurality of insulating layers is a low-conductivity layer (Col. 5, Ln. 28-60 and Col. 6, Ln. 8-19). Regarding Claim 10 Modified Thunhorst teaches all the limitations of claim 8 as shown above. Thunhorst further teaches the low-conductivity layer is a low-conductivity fabric, comprising a plurality of fiber tows (Col. 5, Ln. 28-60). Claim(s) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over modified Thunhorst as applied to claim 1 above, and further in view of Joubert Des Ouches et al. (US 11346499) (hereinafter Joubert Des Ouches). Regarding Claim 3 Modified Thunhorst teaches all the limitations of claim 1 as shown above. Modified Thunhorst does not teach the outer composite layer may include a hydrogen sensor to detect hydrogen leaking from the chamber. Joubert Des Ouches teaches a composite hydrogen storage tank for storing liquid hydrogen, the composite hydrogen storage tank comprising: a multilayer composite wall (below – Fig. 6) defining a chamber for the liquid hydrogen, the multilayer wall including: an inner composite layer (622”) including a plurality of reinforcing fiber tows surrounded by a matrix, the inner composite layer including an inner surface defining the chamber; a hydrogen barrier layer (e.g. the wall of tank 100) formed on the inner surface of the inner composite layer; an outer composite layer (622’) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix; and a plurality of insulating layers (660/623/622/660’/632’) between the inner composite layer and the outer composite layer (Col. 12, Ln. 36-62). Joubert Des Ouches further teaches the outer composite layer may include a hydrogen sensor to detect hydrogen leaking from the chamber (Col. 3, Ln. 48-53). PNG media_image5.png 421 394 media_image5.png Greyscale Modified Thunhorst and Joubert Des Ouches are analogous inventions in the field of hydrogen storage tanks. It would have been obvious to one skilled in the art at the time of filing to modify the outer composite layer of modified Thunhorst with the teachings of the outer composite layer including a hydrogen sensor of Joubert Des Ouches in order to detect hydrogen leaking from the chamber (Col. 3, Ln. 48-53). Claim(s) 1, 4, 8, 9, 12-14, 17, and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Brunnhofer (US 7743940) in view of Blum et al. (US 5419319) (hereinafter Blum). Regarding Claim 1 Brunnhofer teaches a composite hydrogen storage tank for storing liquid hydrogen (Fig. 2 and 3), the composite hydrogen storage tank comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including: an inner composite layer (5/6/7) including a plurality of reinforcing fiber tows surrounded by a matrix, the inner composite layer including an inner surface defining the chamber; an outer composite layer (20) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix; and a plurality of insulating layers (10/13/15/17) between the inner composite layer and the outer composite layer (Col. 3, Ln. 63 – Col. 5, Ln. 26). PNG media_image6.png 355 433 media_image6.png Greyscale PNG media_image7.png 442 437 media_image7.png Greyscale Brunnhofer does not teach a hydrogen barrier layer formed on the inner surface of the inner composite layer, the hydrogen barrier layer being a metal layer having a thickness from five mils to fifty mils. Blum teaches a composite hydrogen storage tank (Fig. 1 and 3) for storing liquid hydrogen, the composite hydrogen storage tank (10) comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including; a hydrogen barrier layer (14) formed on an inner surface of the tank, the hydrogen barrier layer being a metal layer (16/20) capable of having a thickness from five mils to fifty mils; an outer composite layer (11) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix (Col. 5, Ln. 17 – Col. 6, Ln. 7; and Col. 6, Ln. 60 – Col. 7, Ln. 6). Brunnhofer and Blum are analogous inventions in the field of hydrogen storage tanks. It would have been obvious to one skilled in the art at the time of filing to modify the tank of Brunnhofer with the teachings of the hydrogen barrier layer of Blum in order to provide a hydrogen barrier layer that provides low gas permeability while adding negligible weight to the overall tank (Col. 4, Ln. 60-64). Regarding Claim 4 Brunnhofer in view of Blum (hereinafter “modified Brunnhofer”) teaches all the limitations of claim 1 as shown above. Brunnhofer further teaches one of the plurality of insulating layers is a vacuum layer (13). Regarding Claim 8 Modified Brunnhofer teaches all the limitations of claim 1 as shown above. Brunnhofer further teaches one of the plurality of insulating layers (15/17/40) is a low-conductivity layer. Regarding Claim 9 Modified Brunnhofer teaches all the limitations of claim 8 as shown above. Brunnhofer further teaches the low-conductivity layer (40) is a foam. Regarding Claims 12 and 13 Modified Brunnhofer teaches all the limitations of claim 8 as shown above. Brunnhofer further teaches another one of the plurality of insulating layers is a vacuum layer (13), wherein the vacuum layer is located inward of the low-conductivity layer (15/17), as can be seen in Fig. 3 above. Regarding Claim 14 Modified Brunnhofer teaches all the limitations of claim 1 as shown above. Brunnhofer further teaches a plurality of connectors (11/12/55) positioned between the inner composite layer and the outer composite layer (Col. 4, Ln. 45-55 and Col. 5, Ln. 26-36). Regarding Claim 17 Modified Brunnhofer teaches all the limitations of claim 14 as shown above. Brunnhofer further teaches the composite hydrogen storage tank has a longitudinal direction, the plurality of connectors being spaced apart from each other in the longitudinal direction, as can be seen in Fig. 2 above. Regarding Claim 19 Modified Brunnhofer teaches all the limitations of claim 14 as shown above. Brunnhofer further teaches each connector of the plurality of connectors is a composite connector including a plurality of reinforcing fiber tows surrounded by a matrix (Col. 4, Ln. 24-32). Claim(s) 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over modified Brunnhofer as applied to claim 8 above, and further in view of Wowk et al. (US 7278278) (hereinafter Wowk). Regarding Claim 11 Modified Brunnhofer teaches all the limitations of claim 8 as shown above. Specifically, modified Brunnhofer teaches one of the plurality of insulating layers (13) is a low-conductivity layer. Modified Brunnhofer does not teach the low-conductivity layer is a low-conductivity fabric comprising a plurality of fiber tows or a porous material, the low-conductivity layer having a soft vacuum with a pressure from 0.2 psi to 0.5 psi. Wowk teaches a storage system comprising: a multilayer wall defining a chamber for storing contents therein. Wowk further teaches a low-conductivity layer surrounding the chamber, wherein low-conductivity layer is a porous material, the low-conductivity layer having a soft vacuum (Col. 11, Ln. 59 – Col. 12, Ln. 6). Wowk does not specifically teach “the soft vacuum with a pressure from 0.2 psi to 0.5 psi”, however according to the Applicant’s specification, a soft vacuum has a typical pressure of 0.2 to 0.5 psi (Paragraph [0069]). Modified Brunnhofer and Wowk are analogous inventions in the field of insulated storage systems. It would have been obvious to one skilled in the art at the time of filing to modify the a low-conductivity layer of modified Brunnhofer with the teachings of the low-conductivity layer of Wowk in order to provide an insulating layer that provides greater economy and design flexibility (Col. 11, Ln. 59 – Col. 12, Ln. 1). Claim(s) 16 and 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over modified Brunnhofer as applied to claim 14 above, and further in view of Berner et al. (US 3289423) (hereinafter Berner). Regarding Claim 16 Modified Brunnhofer teaches all the limitations of claim 14 as shown above. Modified Brunnhofer does not teach the composite hydrogen storage tank has a perimetric direction, the plurality of connectors being spaced apart from each other in the perimetric direction. Berner teaches a hydrogen storage tank for storing liquid hydrogen (below – Fig. 1), the hydrogen storage tank comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including: inner layer (2) including an inner surface defining the chamber; and a plurality of insulating layers (4 and 3) between the inner layer and the outer layer; further comprising a plurality of connectors (5) positioned between the inner layer and the outer layer; and wherein the hydrogen storage tank has a perimetric direction, the plurality of connectors being spaced apart from each other in the perimetric direction, as can be seen in Fig. 1 below (Col. 3, Ln. 6-29). PNG media_image8.png 558 576 media_image8.png Greyscale Modified Brunnhofer and Berner are analogous inventions in the field of hydrogen storage tanks having connectors. It would have been obvious to one skilled in the art at the time of filing to modify the tank of modified Brunnhofer (i.e. connectors 55) with the teachings of perimetric spaced connectors of Berner in order to provide a more uniform spacing support around the perimeter of the tank. Regarding Claim 18 Modified Brunnhofer teaches all the limitations of claim 14 as shown above. Modified Brunnhofer further teaches the composite hydrogen storage tank has a longitudinal direction and a perimetric direction, the plurality of connectors being arrayed in a linear array extending in the longitudinal direction, as can be seen in Fig. 2 above. Modified Brunnhofer does not teach the plurality of connectors within each linear array being spaced apart from each other, each linear array of the plurality of linear arrays being spaced apart from each other in the perimetric direction. Berner teaches a hydrogen storage tank for storing liquid hydrogen (Fig. 1), the hydrogen storage tank comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including: inner layer (2) including an inner surface defining the chamber; and a plurality of insulating layers (4 and 3) between the inner layer and the outer layer; further comprising a plurality of connectors (5) positioned between the inner layer and the outer layer; and wherein the composite hydrogen storage tank has a longitudinal direction and a perimetric direction, the plurality of connectors being arrayed in a plurality of linear arrays, each linear array extending in the longitudinal direction and the plurality of connectors within each linear array being spaced apart from each other, each linear array of the plurality of linear arrays being spaced apart from each other in the perimetric direction (Col. 3, Ln. 6-29). Modified Brunnhofer and Berner are analogous inventions in the field of hydrogen storage tanks having connectors. It would have been obvious to one skilled in the art at the time of filing to modify the tank of modified Brunnhofer (i.e. connectors 55) with the teachings of array of perimetric spaced connectors of Berner in order to provide a more uniform spacing support around the perimeter of the tank. Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over a second interpretation of Brunnhofer (US 7743940), in view of Blum et al. (US 5419319) (hereinafter Blum). Regarding Claim 20 Brunnhofer teaches a composite hydrogen storage tank for storing liquid hydrogen (Fig. 2 and 3), the composite hydrogen storage tank comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including: an inner composite layer (5/6/7) including a plurality of reinforcing fiber tows surrounded by a matrix, the inner composite layer including an inner surface defining the chamber; an outer composite layer (20) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix; and a plurality of insulating layers (10/13/15/17) between the inner composite layer and the outer composite layer; a plurality of connectors (11/12/55) positioned between the inner composite layer and the outer composite layer; and each connector of the plurality of connectors is a composite connector including a plurality of reinforcing fiber tows surrounded by a matrix; and the plurality of connectors is integrally formed with the inner composite layer (Col. 3, Ln. 63 – Col. 5, Ln. 36). Brunnhofer does not teach a hydrogen barrier layer formed on the inner surface of the inner composite layer, the hydrogen barrier layer being a metal layer having a thickness from five mils to fifty mils; and the plurality of connectors is integrally formed with the outer composite layer. At the time of filing, it would have been an obvious matter of design choice to a person of ordinary skill in the art to make the plurality of connectors integrally formed with the outer composite layer, since it has been held that rearranging parts of an invention involves only routine skill in the art. See MPEP 2144.04(V)(B). As such, the claim of teach the plurality of connectors being integrally formed with the outer composite layer does not provide patentable distinction over the prior art of record. Blum teaches a composite hydrogen storage tank (Fig. 1 and 3) for storing liquid hydrogen, the composite hydrogen storage tank (10) comprising: a multilayer composite wall defining a chamber for the liquid hydrogen, the multilayer wall including; a hydrogen barrier layer (14) formed on an inner surface of the tank, the hydrogen barrier layer being a metal layer (16/20) capable of having a thickness from five mils to fifty mils; an outer composite layer (11) forming an exterior of the composite hydrogen storage tank, the outer composite layer including a plurality of reinforcing fiber tows surrounded by a matrix (Col. 5, Ln. 17 – Col. 6, Ln. 7; and Col. 6, Ln. 60 – Col. 7, Ln. 6). Brunnhofer and Blum are analogous inventions in the field of hydrogen storage tanks. It would have been obvious to one skilled in the art at the time of filing to modify the tank of Brunnhofer with the teachings of the hydrogen barrier layer of Blum in order to provide a hydrogen barrier layer that provides low gas permeability while adding negligible weight to the overall tank (Col. 4, Ln. 60-64). Allowable Subject Matter Claims 21 and 22 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. The following is a statement of reasons for the indication of allowable subject matter: Closest prior art – Thunhorst in view of Blum (cited above) – teaches a majority of the Applicant’s claimed invention, as shown above. However, the closest prior art does not teach the intermediate hydrogen barrier layer is a metal layer, wherein the intermediate hydrogen barrier layer has a thickness from five mils to fifty mils. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 JENNIFER CASTRIOTTA whose telephone number is (571)270-5279. The examiner can normally be reached Monday - Friday 9am-5pm. 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, Nathan Jenness can be reached at (571) 270-5055. 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. /JENNIFER CASTRIOTTA/Examiner, Art Unit 3733 /NATHAN J JENNESS/Supervisory Patent Examiner, Art Unit 3733 24 August 2026
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Prosecution Timeline

Dec 27, 2024
Application Filed
Jan 08, 2026
Non-Final Rejection mailed — §103
Apr 07, 2026
Response Filed
Aug 27, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
62%
Grant Probability
91%
With Interview (+28.8%)
2y 6m (~9m remaining)
Median Time to Grant
Moderate
PTA Risk
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