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`Docket No: P180060US00
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`REMARKS
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`Upon entry of this amendment claim 1 is pending. Claim 1 is herein amended. Support
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`for the amendments is at least found at paragraphs [0026] and [0039] as well as Fig. 2 in the
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`application as published. Claims 2-10 are cancelled herein without prejudice or disclaimer.
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`A licant’s Res onse to the Claim Re'ections under 35 U.S.C. 102
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`Claim 8 is rejected under 35 U.S.C. § 102(a)(1) as being anticipated by Kim et al.
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`(US Publication 2013/0143109).
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`Claims 8-10 are rejected under 35 U.S.C. § 102(a)(1) as being anticipated by Byun et
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`al. (US Publication 2011/0171516).
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`As noted above, applicant has herein cancelled claims 8-10.
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`In light thereof, applicant
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`respectfully submits that the rejections are now moot.
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`A licant’s Res onse to the Claim Re'ections under 35 U.S.C.
`103
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`Claim 1, 2, 5 and 6 are rejected under 35 U.S.C. § 103 as being unpatentable
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`over Kim et al.
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`(US Publication 2013/0143109)
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`in View of Aoshima et al.
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`(US
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`Publication 2003/0031923).
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`In response thereto, applicants respectfully submit that the claims as now presented are
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`not obvious over Kim in view of Aoshima for at least the reason that the combination does not
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`provide for all the aspects of the claims, nor is there any rationale prompting a skilled artisan to
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`modify the combination so as to derive the current invention.
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`Specifically, Kim in view of Aoshima at least fails to provide for the aspects of parent
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`claim 1 regarding the arrangement between the positive electrode terminal and the positive
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`Application No: 15/749,561
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`Docket No: P18006OUSOO
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`electrode lead-stacked part being related to the arrangement between the negative electrode
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`terminal and the negative electrode lead-stacked part.
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`Per page 8 bridging page 9 of the Office Action, the rejection primarily relies upon Kim
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`Figs. 5, 7 and 10-12 as teaching multiple stacked electrode bodies each including a plurality of
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`single plate cells,
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`in which lead-stacked parts extending from the stacked electrode body are
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`connected to a positive electrode terminal and a negative electrode terminal. The rejection
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`acknowledges that Kim does not disclose the single plate cells in each block to be 20 or more
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`and the positive electrode lead and the negative electrode leads each have a thickness of 20
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`microns or less. For this aspect, the rejection relies on the secondary reference, Aoshima.
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`Aoshima is not relied upon for the other aspects of claim 1.
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`In response thereto, applicant respectfully notes that although Kim teaches how the
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`positive electrode lead-stacked part is joined with the positive electrode terminal, the reference is
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`silent as to how the negative electrode lead-stacked part is joined with the negative electrode
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`terminal. As such, Kim fails to explicitly provide for the aspect of amended claim 1 which
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`requires that the arrangement between the positive electrode terminal and the positive electrode
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`lead-stacked part be related to the arrangement between the negative electrode terminal and the
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`negative electrode lead-stacked part.
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`Specifically, Kim per Fig. 5 thereof discloses an arrangement in which a pair of positive
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`electrode lead-stacked parts are connected to a positive electrode terminal, and a pair of negative
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`electrode lead-stacked parts are connected to a negative electrode terminal.
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`Application No: 15/749,561
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`Docket No: P18006OUSOO
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`Nor do relied on Figs. 9 and 10 of Kim
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`1““; . .9
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`disclose the arrangements of the structures as
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`required by the present invention. Specifically,
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`Kim per Fig. 9 thereof discloses a positive
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`electrode terminal sandwiched between a pair of
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`FR}. 3}}
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`positive electrode lead-stacked parts. Again, the
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`disclosure by Kim does not
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`reveal how a
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`negative electrode terminal is connected with a
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`pair of negative electrode lead-stacked parts.
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`such assembly must include connecting a pair of
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`Obtaining the claimed structure would require
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`the electrode assembly per Fig. 9 of Kim be
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`formed in a particular manner.
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`For example,
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`negative
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`electrode
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`lead-stacked
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`parts
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`onto
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`different, opposite surfaces of the negative electrode terminal, wherein a first negative electrode
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`lead-stacked part extending from the upper single-plate-cell stacked electrode body has its upper
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`surface joining a lower surface of the negative electrode terminal, and a second negative
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`electrode lead-stacked part extending from the lower single-plate-cell stacked electrode body has
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`its lower surface joining an upper surface of the negative electrode terminal.
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`As another example, the electrode assembly per Fig. 9 of Kim must include a folded end
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`in each of the pair of negative electrode lead-stacked parts for connection with the negative
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`electrode terminal. Moreover, not only does Fig. 9 of Kim lack the teaching as to the
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`configuration surrounding the negative electrode terminal and the pair of negative electrode lead-
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`Application No: 15/749,561
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`Docket No: P18006OUSOO
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`stacked parts, relied on Fig. 10 of Kim fails to identify the single-plate cells with which the
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`respective positive electrode lead-stacked parts, connected to the positive electrode terminal, are
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`associated.
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`Moreover, there is no viable rationale whereby a skilled artisan may be prompted to
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`modify Kim in view of Aoshima so as to derive the current invention because doing so requires
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`substantial modification to the principles of operation of the device of Kim.
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`Most specifically, to obtain the substantially same structure required by amended claim 1,
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`the device of Kim must undergo extensive modifications, including: (1) folding over the distal
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`end of a first positive electrode lead-stacked part, (2) joining the folded end of the first positive
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`electrode lead-stacked part with the positive electrode terminal, (3) folding over the distal end of
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`a first negative electrode lead-stacked part that extends from the negative electrode plates
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`forming single-plate cells together with the positive electrode plates from which a second
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`positive electrode lead-stacked part
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`(i.e., different from the first positive electrode lead-stacked
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`part) extends, and (4) joining the folded end of the first negative electrode lead-stacked part with
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`the negative electrode terminal. No such modifications are feasible to Kim. Per M.P.E.P.
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`§2143.01.VI when a modification would require a substantial reconstruction and redesign of the
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`elements shown in the primary reference the modification cannot be considered obvious.
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`In short, Kim does not provide for all the aspects of amended claim 1 particularly the
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`reference does not provide for a specific arrangement between the negative electrode terminal
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`and negative electrode lead-stacked parts, as claimed. Aoshima does not cure the deficiency.
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`There is no rationale prompting a skilled artisan to modify Kim in view of Aoshima to
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`incorporate at least these missing aspects as doing so would be contrary to the intended operation
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`of the structure of Kim.
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`Application No: 15/749,561
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`Docket No: P18006OUSOO
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`Wherefore, applicant respectfully submits that parent claim 1 as now presented is not
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`obvious over Kim in view of Aoshima.
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`Claim 1, 2 and 7 are rejected under 35 U.S.C. § 103 as being unpatentable over
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`Byun et al. in View of Aoshima et al. (US Publication 2003/0031923).
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`In response thereto, applicants respectfully submit that the claims as now presented are
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`not obvious over Byun in view of Aoshima for at least the reason that the combination does not
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`provide for all the aspects of the claims, nor is there any rationale prompting a skilled artisan to
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`modify the combination so as to derive the current invention.
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`Specifically, Byun in view of Aoshima at least fails to provide for the aspects of parent
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`claim 1 regarding the arrangement between the positive electrode terminal and the positive
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`electrode lead-stacked part being related to the arrangement between the negative electrode
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`terminal and the negative electrode lead-stacked part.
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`Per page 11 bridging page 12, the rejection asserts that Byun discloses a plurality of
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`wound electrode assemblies, wherein a positive current collecting lead tab and a negative current
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`collecting lead tab are bonded to a positive electrode uncoated region and a negative electrode
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`uncoated region, respectively. The rejection acknowledges that Byun does not disclose the single
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`plate cells in each block to be 20 or more and the positive electrode lead and the negative
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`electrode leads each have a thickness of 20 microns or less. For this aspect, the rejection relies
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`on the secondary reference, Aoshima. Aoshima is not relied upon for the other aspects of
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`claim 1.
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`Application No: 15/749,561
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`Docket No: P18006OUSOO
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`In response thereto, applicant notes that each electrode assembly of Byun represents a
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`single-plate cell, and the positive current collecting lead tab is bonded to the positive electrode
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`uncoated region of each electrode assembly. Hence, Byun fails to provide for at least the aspects
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`of amended claim 1 regarding the positive electrode lead-stacked part being formed by joining
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`the first positive electrode lead and the second positive electrode lead to each other.
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`In short,
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`Byun fails to disclose an arrangement in which the positive electrode uncoated regions of the
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`different electrode assemblies are joined to each other, so as to obtain the substantially same
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`structure as now recited in amended claim 1.
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`Moreover, there is no viable rationale prompting a skilled artisan to modify Byun in view
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`of Aoshima to derive at least these missing aspects. For example, to add the missing feature to
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`the device of Byun would require further extending the positive electrode uncoated regions in the
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`axial direction of the wound electrode assemblies, which involves extremely precise welding
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`between the uncoated regions which have substantial thicknesses. The skilled artisan readily
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`ascertains that such a modification is not conducive to the structure of the stacks employed by
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`Byun.
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`In summary, Byun does not provide for at least the aspects of parent claim 1 regarding
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`the positive electrode lead-stacked part being formed by joining the first positive electrode lead
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`and the second positive electrode lead to each other. Aoshima does not cure this deficiency.
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`Finally, there is no rationale prompting a skilled artisan to modify Byun in view of Aoshima to
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`derive these missing aspects.
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`In view of the foregoing amendments and accompanying remarks, it is submitted that all
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`pending claims are in condition for allowance. A prompt and favorable reconsideration of the
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`rejection and an indication of allowability of all pending claims are earnestly solicited.
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`10
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`
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`Application No: 15/749,561
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`Docket No: P18006OUSOO
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`If the Examiner believes that there are issues remaining to be resolved in this application,
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`the Examiner is invited to contact the undersigned attorney at the telephone number indicated
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`below to arrange for an interview to expedite and complete prosecution of this case.
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`If this paper is not timely filed, Applicants respectfully petition for an appropriate
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`extension of time. The fees for such an extension or any other fees that may be due with respect
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`to this paper may be charged to Deposit Account No. 50-2866.
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`Respectfully submitted,
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`WESTERMAN, HATTORI, DANIELS & ADRIAN, LLP
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`/Michael J. Caridi/
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`Michael J. Caridi
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`Attorney for Applicants
`Registration No. 56,171
`Telephone: 703-827-3800
`Facsimile: 571-395-8753
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`MJC/af
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`11
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