Prosecution Insights
Last updated: August 17, 2026
Application No. 19/277,167

ENERGY STORAGE SYSTEM

Non-Final OA §103
Filed
Jul 22, 2025
Priority
Oct 18, 2024 — RE 10-2024-0142763
Examiner
INGE, JOSEPH N
Art Unit
2836
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Samsung SDI Co., Ltd.
OA Round
1 (Non-Final)
75%
Grant Probability
Favorable
1-2
OA Rounds
1y 9m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allowance Rate
404 granted / 536 resolved
+7.4% vs TC avg
Strong +24% interview lift
Without
With
+24.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
22 currently pending
Career history
552
Total Applications
across all art units

Statute-Specific Performance

§101
0.9%
-39.1% vs TC avg
§103
74.3%
+34.3% vs TC avg
§102
15.8%
-24.2% vs TC avg
§112
5.6%
-34.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 536 resolved cases

Office Action

§103
CTNF 19/277,167 CTNF 89948 DETAILED ACTION Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. Claim Objections 07-29-01 AIA Claim 1 is objected to because of the following informalities: claim 1 recites the claim element “the PCS” before it has been properly introduced. Said introduction occurs later in the claim stating, “a power conversion system (PCS)”. The examiner will read the claim as, “…the battery racks and a power conversion system (PCS) ;… the PCS configured to:…” (emphasis added) . Appropriate correction is required. Claim Rejections - 35 USC § 103 07-20-aia AIA 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. 07-21-aia AIA Claim (s) 1, 4, and 8-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yun (U.S. Patent Publication Number 2014/0079960) in view of Kim (U.S. Patent Publication Number 2014/0347013) . Regarding Claim 1: Yun discloses an energy storage system (Fig. 1, energy storage system 1) comprising: a battery container (Figs. 1-2, battery system 20) comprising: sub-battery containers comprising battery racks (Fig. 2, plurality of server racks 200s comprising slave racks 200s1 and 200s2 with battery racks 220, and their related discussion; see, at least, paragraph 0048) ; and a master battery container (Fig. 2, master rack 200m) comprising: a battery rack comprising a battery module (Fig. 2, master rack 200m comprising battery rack 220, and its related discussion; see, at least, paragraph 0048) ; a system battery management system (BMS) (Fig. 2, master BMS 210m and its related discussion) configured to monitor states of, and to control operations of, the battery racks of the master battery container and the sub-battery containers (Fig. 2, master BMS 210m and its related discussion; see, at least, paragraphs 0048-0058, etc. which disclose the master BMS 210m collects data from its own battery rack 220 and data of the slave racks 200s1 and 200s2, as well as control an operation of each of the slave racks and its own corresponding rack and protective circuit) ; a master programmable logic controller (PLC) (Fig. 2, integrated controller 15 and its related discussion; see, at least, paragraphs 0040, 0056, 0062-0063, etc. which disclose the integrated controller 15 controlling operations according to firmware, algorithms, results of monitoring, etc.) configured to monitor a state of the master battery container, to transmit a monitoring result to the system BMS, and to transmit data to, or receive data from, the system BMS (Fig. 2, integrated controller 15 and its related discussion; see, at least, paragraphs 0039-0041, 0045-0053, 0058-0065, etc. which discloses the integrated controller 15 monitors the states of the battery system and communicates with the master BMS 210m through data communication bus 241) ; a first switch (Fig. 5, first switch 233) configured to be controlled by a switching control signal from the master PLC based on a request from the system BMS to control electrical connection between one or more of the battery racks and a power conversion system (PCS) (Figs. 1-2, integrated controller 15, power conversion system 10 with converting unit 11, inverter 13 and converter 14, battery system 20, etc., and their related discussion; see, at least, paragraphs 0040, 0047-0053, 0058-0061, 0063-0065, etc. which disclose the integrated control 15 controls the battery system 20 to be charged and discharged, as well as the integrated controller 15 transmitting a command to the master BMS 210m for subsequent operations based upon the respective communication between components) ; and the PCS (Fig. 1, power conversion system 10 with converting unit 11, inverter 13 and converter 14) configured to: convert a direct current power from the battery container into alternating current power, and transmit the alternating current power to a power system (Fig. 1, power conversion system 10 with converting unit 11, inverter 13 and converter 14, and their related discussion; see, at least, paragraphs 0031-0040, etc.) ; and convert alternating current power from the power system into direct current power, and transmit the direct current power to the battery container (Fig. 1, power conversion system 10 with converting unit 11, inverter 13 and converter 14, and their related discussion; see, at least, paragraphs 0031-0040, etc.) wherein the system BMS and the master PLC are further configured to transmit and receive data via a contact communication method (Fig. 2, integrated controller 15, BMS 210m, data communication bus 241, and their related discussion; see, at least, paragraphs 0039-0041, 0045-0053, 0058-0065, etc. which discloses the integrated controller 15 communicates with the master BMS 210m through data communication bus 241) . While Yun discloses a master battery container comprising a battery rack comprising battery modules, Yun fails to teach the inclusion of a plurality of battery racks within the master battery container. Yun also fails to teach a second switch configured to be controlled by a switching control signal of the system BMS to control electrical connection between one or more of the battery modules and the first switch. However, Kim discloses a master battery container comprising: battery racks comprising battery modules (Fig. 2, battery rack 160A including a plurality of battery packs 161A and their related discussion; see, at least, paragraphs 0015, 0057-0069, etc.) ; a first switch (Figs. 2-3, switch S1A and its related discussion) and a second switch (Figs. 3-4, switch unit 1628 as shown) configured to be controlled by a switching control signal of the system BMS to control electrical connection between one or more of the battery modules and the first switch (Figs. 3-4, switch unit 1628 and its related discussion; see, at least, paragraphs 0115, 0122-0126, claim 7, etc. which disclose respective control over the switch unit to control an electrical connection between the plurality of battery modules as shown and the main switches such as S1A) . It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to realize the master battery container as comprising a plurality of battery racks comprising battery modules, as taught within Kim, to provide a scalable and efficient energy storage solution. Furthermore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate a second switch to be controlled, as taught within Kim, to provide greater control over the flow paths of voltage and current, thereby improving overall system efficiency, longevity and safety by establishing a more robust and complete energy storage system capable of connecting or disconnecting components and circuitry as necessary. Regarding Claim 4: Modified Yun teaches the limitations of the preceding claim 1. Modified Yun, in further view of Yun, discloses wherein the system BMS and the master PLC are configured to perform data communication through: a first cable connecting an output contact of the system BMS to an input contact of the master PLC; and a second cable connecting an input contact of the system BMS to an output contact of the master PLC (Fig. 2, master BMS 210m, integrated controller 15, and bus 241, and their related discussion; see, at least, paragraph 0053 which discloses the bus 241 may be a CAN bus) . Regarding Claim 8: Modified Yun teaches the limitations of the preceding claim 1. Modified Yun, in further view of Yun, discloses wherein the system BMS is further configured to transmit or receive data to or from the battery racks based on controller area network (CAN) communication (Fig. 2, master BMS 210m, and bus 242, and their related discussion; see, at least, paragraph 0054 which discloses the bus 242 may be a CAN bus) . Regarding Claim 9: Modified Yun teaches the limitations of the preceding claim 8. Modified Yun, in further view of Yun, discloses wherein the battery racks are configured to transmit or receive data in a daisy chain manner based on the CAN communication (Fig. 2, master BMS 210m, plurality of slave BMS 210s as shown, and bus 242, and their related discussion; see, at least, paragraphs 0054-0058 which discloses the bus 242 may be a CAN bus) . 07-21-aia AIA Claim (s) 7 and 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yun (U.S. Patent Publication Number 2014/0079960) in view of Kim (U.S. Patent Publication Number 2014/0347013) and in further view of Yang et al. (U.S. Patent Publication Number 2024/0332647) . Regarding Claim 7: Modified Yun teaches the limitations of the preceding claim 1. Modified Yun fails to teach comprising an energy management system configured to integrally manage an operation of the energy storage system, and to transmit or receive data to or from the system BMS based on transmission control protocol/internet protocol (TCP/IP) communication. However, Yang et al. discloses an energy management system configured to integrally manage an operation of the energy storage system, and to transmit or receive data to or from the system BMS based on transmission control protocol/internet protocol (TCP/IP) communication (see, at least, paragraph 0091 which discloses communication through TCP/IP communication) . It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate an energy management system configured to transmit or receive data based on TCP/IP communication, as taught within Yang, to realize high-speed, real-time data transfer with low-latency communication properties, thereby enhancing system speed, control, and reliability. Regarding Claim 10: Modified Yun teaches the limitations of the preceding claim 1. Modified Yun fails to teach wherein the master PLC is further configured to transmit or receive data to or from sub-PLCs in the sub-battery containers based on transmission control protocol/internet protocol (TCP/IP) communication. However, Yang et al. discloses the utilization transmission control protocol/internet protocol (TCP/IP) communication (see, at least, paragraph 0091 which discloses communication through TCP/IP communication) . It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to realize communication between components based on TCP/IP communication, as taught within Yang, to realize high-speed, real-time data transfer with low-latency communication properties, thereby enhancing system speed, control, and reliability . Allowable Subject Matter 12-151-08 AIA 07-43 12-51-08 Claim s 2-3 and 5-6 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. 13-03-01 AIA The following is a statement of reasons for the indication of allowable subject matter: Dependent claims 2 and 5 are currently believed to be directed towards a non-obvious improvement over the prior art of record as both claims 2 and 5 further narrow the overall system control and operations with respect towards various signal requests, communication, and subsequent control based upon said communication, to which the prior art neither teaches, nor addresses, and further wherein such modifications to the prior art of record, would potentially render ineffective or in the least teach away from said disclosures. Dependent claims 3 and 6 are objected to as being ultimately dependent upon claims 2 and 5. For these reasons, inter alia, it appears as if claims 2 and 5 were rewritten in independent form, in their entirety , said claims would be in condition for allowance . Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOSEPH N INGE whose telephone number is (571)270-7705. The examiner can normally be reached 10:00-4:00 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, Rexford Barnie can be reached at 571-272-7492. 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. /JOSEPH N INGE/Examiner, Art Unit 2836 Application/Control Number: 19/277,167 Page 2 Art Unit: 2836 Application/Control Number: 19/277,167 Page 3 Art Unit: 2836 Application/Control Number: 19/277,167 Page 4 Art Unit: 2836 Application/Control Number: 19/277,167 Page 5 Art Unit: 2836 Application/Control Number: 19/277,167 Page 6 Art Unit: 2836 Application/Control Number: 19/277,167 Page 7 Art Unit: 2836
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Prosecution Timeline

Jul 22, 2025
Application Filed
Jun 17, 2026
Non-Final Rejection mailed — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
75%
Grant Probability
99%
With Interview (+24.0%)
2y 10m (~1y 9m remaining)
Median Time to Grant
Low
PTA Risk
Based on 536 resolved cases by this examiner. Grant probability derived from career allowance rate.

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