Applicant:
`
`Karol Doktor
`
`PATENT
`
`J7c
`IN.THE UNITED STATES PATENT AND TRADEMARK. OFFICEd7
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`Financial Systems Technology Pty. Ltd. ~ ~
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`Assignee:
`
`Title:
`
`EXPANSION CAPABILITY
`
`Serial No.:
`
`08/439,013
`
`Filed:
`
`Group Art Unit:
`P. Lintz
`Examiner:
`Attorney Docket No.: M-1226-4D us
`
`San Jose, California
`February 20, 1996
`
`COMMISSIONER OF PATENTS AND TRADEMARKS
`Washington, D. C.
`20231
`
`AMENDMENT
`
`Sir:
`
`This is a response to the office action dated August 24,
`
`1995.
`
`Claims 15-30 are pending and remain at issue.
`
`REMARKS
`
`Reiection of Claims 15.18.21.24. and 27-30 under 35 U.S.C. §103
`
`The Examiner rejected Claims 15, 18, 21, 24, and 27-30
`
`under 35 U.S.C. §103 as being unpatentable over Shimaoka et al.
`
`(US Patent No. 4,893,232) and Korth and Silberschatz (Database
`
`System Concepts). Specifically, the Examiner stated that
`
`Claims 15, 18, 21, 24, and 27-30 "essentially claim breaking a
`
`compound query into subqueries and then merging the subqueries
`
`in retrieval of information from a relational database."
`
`Applicant respectfully submits that the Examiner is in error.
`
`The claims of the present application recite specific elements
`
`for a novel method and system of data retrieval which does not
`
`encompass breaking a compound query. Furthermore, Applicant
`
`respectfully submits that the system and method recited by the
`
`claims are radically different from the example cited by the
`
`Examiner in Korth and Silberschatz.
`
`For example, Claim 15 recites
`
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`- 1
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`

`

`PATENT
`
`retrieving from said relational
`database a second entity wherein said
`second entity is related to said first
`entity by said first relation; ...
`
`retrieving from said relational database
`said selected entity wherein said selected
`entity is related to said second entity by
`said second relation.
`
`Therefore, Claim 15 involves multiple queries by "retrieving
`
`... a second entity which is related to a first entity by a
`
`first relationship" and then "retrieving ... said selected
`
`entity" by using a second relationship to the second entity.
`
`As stated by the Examiner, Korth and Silberschatz
`
`discloses a compound query to "select all customers who have a
`
`deposit AND the deposit is from the 'Perryridge branch' with
`
`the intersection of the second entity all customers who have a
`
`loan and the loan is at the 'Perryridge' branch." For this
`
`query, the "selected entity" must be the customer names since
`
`that is the desired result. The method described by Korth and
`
`Silberschatz retrieves a set of customers with a deposit at
`
`Perryridge Branch and then narrows this list by using an
`
`intersect command with a set of customers who have a loan at
`
`the Perryridge branch. Thus Korth and Silberschatz teach to
`
`retrieve two sets of customers, each of which is a superset of
`
`.the "selected" entity or entities, and then find the
`
`intersection of the two sets to obtain the "selected" entity or
`
`entities.
`
`In Korth and Silberschatz, there is no second entity
`
`since the customers are the selected entities which are then
`
`reduced by intersection with a separate query.
`
`The Examiner also cited Korth and Silberschatz pages as
`
`showing "that a method of 'Query· optimization' involved
`
`breaking down a compound query into multiple subqueries (page
`
`303-305) by a selection operation on each subquery. Applicant
`
`respectfully submits that the examples given on pages 303-305
`
`of Korth and Silberschatz do not. teach or suggest the specific
`
`system recited in Claim 15.
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`- 2 -
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`

`

`PATENT
`
`The first example on page 303 is to "Find the assets and
`
`name of all banks who have depositors living in Port Chester."
`
`The search is given as project (or print) the branch-name and
`assets of the result of the s~lection that customer-city = Port
`
`Chester in the natural joining of the customer relation, the
`
`deposit relation, and the branch relation.
`
`In other words, the
`
`customer relation, the deposit relation, and the branch
`
`relation are combined, then those tuples (in this case each
`
`tuple would include customer-name, street, customer-city,
`
`branch-name, account-number, balance, and assets) in which the
`
`customers lives in Port Chester are selected and their branch
`
`name and assets are printed. Thus in this example only one
`
`retrieval is performed. Consequently, this example can not
`
`disclose "retrieving ... a second entity" and "retrieving ...
`
`said selected entity" as recited in Claim 15.
`
`In the example given on page 304, the example above is
`
`modified "to restrict attention to customers with a balance
`
`over $1000." Korth and Silberschatz, p. 304. Through the
`
`optimization techniques outlined on page 304 the final query
`
`becomes the natural joining of the subset of the customer
`
`relation in which the customer city is Port Chester and the
`
`subset of the deposit relation in which the balance is greater
`
`than 1000. The goal of the optimization and indeed the end
`
`result is that the two queries are completely independent. The
`
`final entity is arrived by joining the results of the two
`
`separate queries. Therefore this example does not teach or
`
`suggest "retrieving ... a second entity which is related to a
`
`first entity by a first relationship" and then "retrieving
`
`said selected entity" by using a second relationship to the.
`
`second entity.
`
`Therefore, Applicant respectfully submits that the
`
`Examiner has failed to cite a reference which teaches
`
`"retrieving .. a
`
`second ~ntity [which] is related to said
`
`first entity by said first relation" and "retrieving ... said
`
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`

`PATENT
`
`selected entity [which] is related to said second entity" as
`
`recited in Claim 15. Consequently, Applicant respectfully
`
`requests reconsiderat'ion and withdrawal of the rejection of
`
`Claim 15.
`
`Applicant respectfully requests the withdrawal of the
`
`objection to Claims 16 and 17, which are dependent upon Claim
`
`15, due to the patentability of Claim 15 as explained above.
`
`Claim 18 is similar to Claim 15 except that a first group
`
`of entities and selected group of entities are retrieved.
`
`Applicant respectfully submits that the arguments given above
`
`with regards to Claim 15 are equally applicable to Claim 18.
`
`Therefore, Applicant respectfully requests reconsideration and
`
`withdrawal of the rejection of Claim 18.
`
`Applicant also respectfully requests the withdrawal of the
`
`objection to Claims 19 and 20, which are dependent upon Claim
`
`18, due to the patentability of Claim 18 as explained above.
`
`Claims 21 and 24 are method claims which correspond to
`
`Claims 15 and 18, respectively. Applicant respectfully submits
`
`that the arguments given above with respect to Claims 15 and 18
`
`are equally applicable to Claims 21 and 24. Therefore,
`
`Applicant respectfully requests reconsideration and withdrawal
`
`of the rejections of Claim 21 and 24.
`
`Applicant also respectfully requests the withdrawal of the
`
`objection to Claims 22, 23, 25, and 26, which are dependent
`
`upon Claims 21 or 24, due to the patentability of Claims 21 and
`
`24 as explained above.
`
`Claims 27 and 29 are very similar to Claims 15 and 18,
`
`respectively, except that the first search path record does. not
`
`necessarily identify a first entity. However Claims 27 and 29
`
`recites "retrieving· ... a first entity" and "retrieving
`
`said selected entity wherein said selected entity is related to
`
`said first entity by said second relation."
`
`As _explained
`
`above with respect to Claim 15, the Examiner has not cited any
`
`reference which teaches or suggest this feature of Claims 27
`
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`

`PATENT
`
`and 29. Therefore, Applicant respectfully requests
`
`reconsideration and withdrawal of the rejection of Claims 27
`
`and 29.
`
`Claims 28 and 30 are similar to Claims 27 and 29 except
`
`that a first group of entities and selected group of entities
`
`are retrieved. Applicant respectfully submits that the
`
`arguments given above with regards to Claims 27 and 29 are
`
`equally applicable to Claims 28 and 30. Therefore, Applicant
`
`respectfully requests reconsideration and withdrawal of the
`
`rejections of Claims 28 and 30.
`
`Conclusion
`
`Therefore, Applicant respectfully submits that all claims
`
`at issue, i.e. Claims 15-30, are patentable over Shimaoka et
`
`al. in light of Korth and Silberschatz and that Claims 15-30
`
`are in a condition for allowance. Accordi.ngly, allowance of
`
`Applicant's Claims 15-30 is respectfully requested.
`
`If the
`
`Examiner's next action is other than entry of this amendment
`
`and allowance of all pending claims, the Examiner is requested
`
`to telephone Applicant's attorney at (408) 453-9200.
`
`Respectfully submitted,
`
`£.~{({;{?---.A
`
`Attorney for Applicant
`Reg. No. 25,246
`
`I hereby certify that this correspondence is being deposited with the
`United States Postal Service as first class mail in an envelope
`addressed to: Comm.Jl;sionerof Patents and Trademarks. Washington,
`D.C., 20231, on C.../t- L •
`19_<i.
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`Date of Signature I
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