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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 06/02/2026 has been entered.
Response to Amendment
In response to the amendments filed 05/10/2026:
Claims 1, 5, and 8-20 are pending in the current application. Claims 2-4 and 6-7 have been canceled. Claims 1 and 8-9 have been amended.
The previous prior art rejection is withdrawn in light of the amendment. However, a new prior art rejection is applied. All changed made to the rejection are necessitated by the amendment.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1, 5, and 8-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention.
Claim 1 recites “…each of the plurality of the current limiters is also directly connected to two pouch battery cells belonging to two different parallel units of the plurality of parallel units…”.
The disclosure teaches “the first connection member 60 is connected to the electrode leads of the pouch battery cells 21 in different parallel units 20 to form the series circuit, and the current limiter 40 is connected to the electrode leads of different pouch battery cells 21 in the same parallel unit 20 to form the parallel circuit” (P136-137.143). Applicant relies on Fig. 6 to teach the above limitation; however, Fig. 6, and the description of Fig. 6 show and recite “the battery device 100 includes two parallel units 20, where each parallel unit 20 includes four pouch battery cells 21, and the four pouch battery cells 21 are connected in parallel to form three parallel circuits. The four pouch battery cells 21 of the two parallel battery cells 20 are connected in series in pairs, forming four series circuits. Each parallel circuit is provided with the current limiter 40” (P117).
Therefore, the current limiter is only directly connected to two pouch batteries in the same parallel unit. One of ordinary skill in the art would not know how to create a circuit with the unsupported new limitation and achieve the technical advantage of directing current.
Claims 5 and 8-20 are rejected for depending on claim 1.
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.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claims 1, 5, 10-11, and 14-20 are rejected under 35 U.S.C. 103 as being unpatentable over Park et al. (US 20220336902) in view of Stefan et al. (EP2200109B1),
Regarding claim 1, Park teaches a battery device, comprising:
a plurality of thermally conductive housings 110; a plurality of parallel units 110, wherein the parallel unit comprises a plurality of pouch battery cells 200 connected in parallel, and one thermally conductive housing 110 correspondingly accommodates the plurality of pouch battery cells in one parallel unit (P99.116-117);
wherein the thermally conductive housing 110 is provided with at least one open end surface, the battery device comprises a cold plate 510, the open end surface faces toward the cold plate 510, and the thermally conductive housing 110 is connected to the cold plate or the pouch battery cells are connected to the cold plate for heat dissipation, wherein a gap is provided between a side of the pouch battery cells proximal to the open end surface and the cold plate, and the gap is filled with a thermally conductive adhesive 130 (P116-133; Fig. 3-11).
Park teaches an open end surface with a gap filled with a thermally conductive adhesive, but is silent in teaching wherein an end part of the open end surface is provided with a limiting part, and the limiting part protrudes towards an interior of the thermally conductive housing and is arranged between the pouch battery cells and the open end surface.
However, Stefan teaches a known configuration for a thermal holder that ensures permanent thermal contact of cells includes a cold plate 120 where the thermal housing 100 may be provided with at least one open end surface, the open end surface faces toward the cold plate 120, and the thermally conductive housing is connected to the cold plate 120 or the pouch battery cells are connected to the cold plate for heat dissipation, wherein a gap is provided between a side of the battery cells proximal to the open end surface and the cold plate 120, wherein an end part of the open end surface is provided with a limiting part, or wing/bend/arch/lyra/sheet 410/150, and the limiting part 410 protrudes towards an interior of the thermally conductive housing 100 and is arranged between the battery cells and the open end surface (P28.33-36; Fig. 5B-E.13-14A.16). This configuration leads to extended service life. It is also taught that having arches/bends/wings in the contour of such housing to prevent sharp edges from projecting in the cell direction to minimize risk of mechanical damage and prevent slipping of the cells (P26.28.55).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant application to use a configuration of a battery device with a thermal plate and the thermally conductive housing of Park comprising at least one open end surface, the open end surface faces toward the cold plate, and the thermally conductive housing is connected to the cold plate or the pouch battery cells are connected to the cold plate for heat dissipation, wherein a gap is provided between a side of the pouch battery cells proximal to the open end surface and the cold plate, wherein an end part of the open end surface is provided with a limiting part, and the limiting part protrudes towards an interior of the thermally conductive housing and is arranged between the pouch battery cells and the open end surface, as taught by Stefan as a known arrangement to hold cells in improving thermal contact and service life.
It would have been obvious to still fill this gap with the thermally conductive adhesive of Park to further increase heat transfer rate of thermal energy (P128)
Modified Park teaches the pouch battery cells may be connected to each other in parallel and units in series, via any configuration and each of the plurality of pouch battery cells comprises two electrode leads leading out in two opposite directions of the pouch battery cell, (P61-74.84.92.165.179; Fig. 2-11), but is silent in teaching a parallel circuit is provided between at least two pouch battery cells of the parallel unit; a series unit, wherein the series unit comprises the pouch battery cells connected in series and separately located in the plurality of parallel units, and a circuit between two pouch battery cells of different parallel units that are connected in series is a series circuit; and a plurality of current limiters, wherein any of the parallel circuits is provided with the current limiter, and the current limiter is positioned outside the series circuit and configured for limiting the current in the corresponding parallel circuit, wherein each of the plurality of pouch battery cells comprises two electrode leads leading out in two opposite directions of the pouch battery cell, the battery device comprises a plurality of first connection members, each of the plurality of first connection members is a wire directly connecting the electrode leads of the pouch battery cells in different parallel units to form the series circuit, and each of the plurality of the current limiters is directly connected to the electrode leads of different pouch battery cells in the same parallel unit to form the parallel circuit, each of the plurality of the current limiters is also directly connected to two pouch battery cells belonging to two different parallel units of the plurality of parallel units, a resistance of the current limiter is greater than a resistance of the first connection member.
However, Beranger, related to electrical connection within a battery device, teaches a plurality of parallel units, or stages Eji each parallel unit comprising a plurality of battery cells, a parallel circuit between at least two cells of the parallel unit, and a series unit, or branch Brj comprising a series circuit connecting battery cells of different parallel units and separately located in the plurality of units connected in series, each circuit connected to opposite electrode leads (P27-39.50.63). The first connection member is a taught as a well-known wire, or fuse to prevent overheating and risk of fire (P11-12).
A plurality of current limiters, wherein any of the parallel circuits is provided with the current limiter, and the current limiter is positioned outside the series circuit and configured for limiting the current in the corresponding parallel circuit, each of the plurality of the current limiters is directly connected to the electrode leads of different pouch battery cells in the same parallel unit to form the parallel circuit (P50-51.60-63.67; Fig. 2-4), each of the plurality of the current limiters is also directly connected to two pouch battery cells belonging to two different parallel units of the plurality of parallel units (P74-76; Fig. 9) the resistance of the current limiter is greater than that of the first connection member (P50.61-67.76-77), included to provide protection for the cells from overcurrent during malfunction and to allow a battery to continue to be used by enabling all of the functional cells to compensate for the failure of a short-circuited cell (P50-51.63.67).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant application to use the circuitry as taught by Beranger in the device of modified Park with the first connection member as a wire, and a plurality of current limiters to limit the current within a set of parallel connected cells and series connections to provide safety, protection, and functionality. Furthermore, it would have been obvious to one of ordinary skill in the art to have the parallel connection formed with the cells of each housing, and the series connection between cells of different parallel units (as taught by Beringer) as a finite number of identified and predictable connections that one would have had a reasonable expectation that the combination would work for its intended purpose. The mere rearrangement of parts, without any new or unexpected results, is within the ambit of a person of ordinary skill in the art.
The rationale to support a conclusion that the claim would have been obvious is that a method of enhancing a particular class of devices (methods, or products) has been made part of the ordinary capabilities of one skilled in the art based upon the teaching of such improvement in other situations. One of ordinary skill in the art would have been capable of applying this known method of enhancement to a "base" device (method, or product) in the prior art and the results would have been predictable to one of ordinary skill in the art. MPEP 2143 C
Regarding claim 5, modified Park in view of Stefan teaches the thermally conductive housing comprises two of the open end surfaces, the two open end surfaces are both provided with the limiting part 410/150, the gap is provided between the side of the pouch battery cells proximal to the open end surfaces and the cold plate 120 (Stefan; P28.31-36.55; Fig. 5B-E.13-14A.16) and, modified Park, is filled with the thermally conductive adhesive, and the thermally conductive adhesive is at least partially located between the two limiting parts so as to thermo-conductively connect the battery cells on one side of the limiting parts to the cold plate on the other side of the limiting parts (Park; P126-130; Fig. 8).
Regarding claim 10, modified Park in view of Beranger teaches the current limiter is configured for limiting the current in the parallel circuit to less than or equal to 6 A, overlapping the claimed range of 20 A. In the case where the claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. MPEP 2144.05- I
Regarding claim 11, modified Park in view of Beranger teaches the resistance of the current limiter is a result effective variable, selected dependent on the type of battery to optimize capacity and provide electrical protection by interrupting the current in the event of overload by limiting the resistance to a cutoff threshold below the maximum charging or discharging current tolerated by a cell (P60-68). One of ordinary skill in the art would therefore seek to find a resistance value depending on the cell type used, that allows capacity to maximized, but prevents short-circuiting.
“[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation.” The discovery of an optimum value of a known result effective variable, without producing any new or unexpected results, is within the ambit of a person of ordinary skill in the art. MPEP § 2144.05, II
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant application to find a resistance value for the current limiter that allows capacity of modified Park to be maximized, but prevents overload, such that, in certain instances dependent on cell type, the resistance is in the claimed range of [0.2 Ω, 1000 Ω]. A prima facie case of obviousness may be established even though a prior art reference does not disclose any particular range but teaches that the claimed parameters are known to affect results or properties. MPEP 2143
Regarding claim 14, modified Park teaches the pouch battery cells can be a secondary battery including an electrode assembly modularized and arranged to obtain a desired power and energy density and may be nickel metal hydride or lithium ion, and is unlimited in type (P2-3.91.93).
Modified Park is silent in teaching the pouch battery cell can be any one of a lithium iron phosphate battery cell, a ternary battery cell, and a solid-state battery cell; however, it would have been obvious to one of ordinary skill in the art to use a lithium iron phosphate battery cell, a ternary battery cell, and a solid-state battery cell in the electric device as a reasonable and predictable method of improving a system that requires a design using such a battery. Furthermore, Beranger of modified Park teaches lithium iron phosphate batteries are well-known batteries used for small, medium or large sized modules in vehicles to provide power and capacity (P1-8). Accommodating a well-known other type of battery that accomplishes the same goal as the pouch cells, of providing a battery pack having large power and capacity, would have been reasonably obvious to one of ordinary skill in designing such a system with the expectation of reasonable success in doing so. MPEP 2143
Regarding claim 15, modified Park teaches an energy storage device, comprising a plurality of the battery devices according to claim 1, the battery device is configured for storing or providing electrical energy (P2-3.14-20.67)
Regarding claim 16, modified Park teaches the battery device is configured for storing or providing electrical energy (P2-3.14-20.67).
Regarding claim 17, modified Park teaches electric device, comprising the energy storage device according to claim 15, wherein the energy storage device is configured for storing or providing electrical energy (P2-3.14-20.67). Accommodating the energy storage module in a well-known electric device that accomplishes the same goal as the energy storage module, of providing charge would have been reasonably obvious to one of ordinary skill in designing such a system with the expectation of reasonable success in doing so. MPEP 2143
Regarding claim 18, modified Park in view of Stefan teaches the limiting part is located between the pouch battery cells and the open end surface and is configured for limiting the positions of the pouch battery cells, so as to prevent the pouch battery cells from falling out of the open end surface during the movement and assembly of the battery device (P28.33-36.55; Fig. 5B-E.13-14A.16).
Regarding claim 19, modified Park in view of Stefan teaches the limiting part is a recess formed on an exterior wall of the heat-conducting casing towards an interior of the casing along a first direction, a dimension of the recess is smaller than a dimension of the open end surface along the first direction, the limiting part does not directly separate the pouch battery cells and the cold plate (P28.33-36.55; Fig. 5B-E.13-14A.16).
Regarding claim 20, modified Park in view of Stefan teaches an accommodating space for the pouch battery cells formed in the thermally conductive housing is in thermal communication with an exterior through an opening between two open end surfaces, the pouch battery cells are in direct contact with the thermally conductive housing (P28.33-36.55; Fig. 5B-E.13-14A.16) and, in Park thermo-conductively connected to the cold plate through the thermally conductive adhesive (P126-130).
Claims 8-9 and 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over modified Park in view of Beranger as applied to at least claim 6 above, and further in view of Johler et al. (US 2016/0254522).
Regarding claim 8, modified Park in view of Beranger teaches a first connection member, or circuitry and the current limiter, or switch/fuse that must be made of an electrically conductive material in order to function (Beranger; P27.52.60-63.75-77). Examiner notes it is well known that circuitry wires have an insulative sheathing, and thus an insulating layer between the connection member and current limiter.
Modified Park is silent in teaching the positioning of the connection member and current limiter; however, Johler, in a similar field of endeavor, teaches a method of connection within a battery device.
A first connection member i.e., metal 49 and a current limiter, or protection device 33/35 are each of an electrically conductive material, and an insulating layer, or insulating carrier strip 51 is provided between the current limiter 33/35 and the first connection member 49 that are connected to an electrode lead 65 of a pouch cell to provide a simple design for multiple battery cells and circuit protection devices with a parallel/series connection. (P27-29.33-36; Fig. 1.4- 6).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant application to have the first connection member and the current limiter of modified Park each of an electrically conductive material, and an insulating layer provided between the current limiter and the first connection member, as taught by Johler, to provide a simple protective design. The rationale to support a conclusion that the claim would have been obvious is that a method of enhancing a particular class of devices (methods, or products) has been made part of the ordinary capabilities of one skilled in the art based upon the teaching of such improvement in other situations. One of ordinary skill in the art would have been capable of applying this known method of enhancement to a "base" device (method, or product) in the prior art and the results would have been predictable to one of ordinary skill in the art. MPEP 2143 C
Furthermore, with respect to the above combination of overall element, the rationale to support a conclusion that the claim would have been obvious is that all the claimed elements were known in the prior art and one skilled in the art could have combined the elements as claimed by known methods with no change in their respective functions, and the combination yielded nothing more than predictable results to one of ordinary skill in the art
Regarding claim 9, modified Park in view of Beranger is silent in teaching wherein on the same pouch battery cell, the first connection member and the current limiter are separately connected to different locations on the same side surface of the electrode lead, or the first connection member and the current limiter are separately connected to different side surfaces of the electrode lead; however, Johler, in a similar field of endeavor, teaches a method of connection within a battery device.
On same pouch battery cell 23, the first connection member 49 and the current limiter 33/35 are separately connected to different locations on the same side surface of the electrode lead 65 to provide a simple design for multiple battery cells and circuit protection devices with a parallel/series connection. (P27-29.33-36; Fig. 1.4- 6).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant application to have on the same pouch battery cell of modified Park, the first connection member and the current limiter are separately connected to different side surfaces of the electrode lead, as taught by Johler, to provide a simple protection design for multiple battery cells.
Regarding claim 12, modified Park teaches the pouch battery cell comprises a body part 212 and an electrode lead 215a/b, the body parts of the plurality of the pouch battery cells in the same thermally conductive housing 110 are arranged in a row in a first direction (P74.80-86.90; Fig. 2-4).
Modified Park in view of Beranger is silent teaching the current limiter is located on one side of the body part in a second direction; the first direction and the second direction are perpendicular to each other; however, Johler, in a similar field of endeavor, teaches a method of connection within a battery device.
A current limiter 35/33 is located on one side of the body part in a second direction; the first direction and the second direction are perpendicular to each other to allow a simple design for multiple battery cells and circuit protection devices with a parallel/series connection (P20-36; Fig. 6).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant application to have the current limiter located on one side of the body part in modified Park in a second direction; the first direction and the second direction are perpendicular to each other, as taught by Johler for a simple protective design.
Regarding claim 13, modified Park teaches the pouch battery cell comprises an outer flexible shell 212/213/214 and an electrode assembly, the electrode assembly comprises an electrode plate part, or plate shaped electrodes and a tab part (P80-96; Fig. 2-4). Modified Park in view of Johler teaches the current limiter is misaligned with the electrode plate part in the first direction (P20-36; Fig.2-6).
Response to Arguments
Applicant argues the new claim limitations overcome the previous showing of obviousness. The amendments overcome the previous rejections. New and amended grounds of rejection are above set forth. New and amended grounds of rejection are necessitated by the claim amendments. Examiner notes the new matter rejection with respect to the current limiter.
Conclusion
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/Amanda Rosenbaum/ Examiner, Art Unit 1752
/Helen Oi K CONLEY/ Primary Examiner, Art Unit 1752
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