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`I hereby certi$, that this conespondence is being
`deposited with the United States Postal Service
`as first class mail in an envelope addressed to:
`Assistant Commissioner for Patents and Trademarks,
`Washington, D,C.20231on May 7. 1999
`Eileen Bull
`
`t+#ff-e fr,u
`
`(signature)
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`-
`
`In re Application of:
`Pavel Mayer et al.
`
`Filed: December 17, 1996
`Serial No.: 08/767,829
`
`Examiner: P. Nguyen
`
`Group Artunit2772
`
`FoT: METHOD AND DEVICE FOR
`PICTORIAL REPRESENTATION
`OF SPACE-RELATED DATA
`
`Attorney Docket l-13416
`
`May 7,1999
`
`AMENDMENT
`
`Hffi#ffi8VffiI}
`$tAY 1 4 t$99
`
`Group 270A
`
`Assistant Commissioner for Patents
`Washington, D.C. 20231
`
`Honorable Sir:
`
`Responsive to the outstanding Examiner's Action dated February I1,1999, applicants
`
`have carefully studied the references cited by the Examiner and the Examiner's comments relative
`
`thereto, Favorable reconsideration of this application is respectfully requested in light of the
`
`following detailed discussion.
`
`GOOGLE EXHIBIT 1005, Page 1 of 19
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`l-13416
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`On page two of the Office Action, the Examiner correctly presumes "that the subject
`
`matter of the various claims was commonly owned at the time any invention covered therein were
`
`made . . . ." The Examiner's presumption is correct even though the application currently names
`
`joint inventors. Therefore, applicants respectfully request the Examiner to evaluate the
`
`application on the grounds that the various claims were commonly owned at the time the
`
`invention was made.
`
`Also, on page two of the Office Action, the Examiner has listed the patent number of
`
`Iwamura et al as "5,602,566." Applicants are assuming that the Examiner intended to list the
`
`Iwamura et al patent number as5,602,564 since 5,602,566 pertains to a different inventor and
`
`completely different subj ect matter.
`
`The Examiner has rejected claims 1-37 under 35 U.S,C. 103(a) as being unpatentable over
`
`Shimada (4,847,788) in view of Iwamura et al (5,602,564). In the Office Action, the Examiner
`
`provided specific reasons for rejecting claims 35-37. The specific points of the Examiner's
`
`rejection of claims 35-37 are addressed first below. The Examiner's rejection of claims l-34
`
`"[d]ue to [their] similarity . . . to claims 35-37. . . under a similar reason" is addressed secondly.
`
`It is respectfully submitted that applicants invention, as defined in claims 7-37, as previously
`
`amended, exhibits novelty over Shimada in view of Iwamura.
`
`Regarding claim 35, the Examiner stated Shimada teaches the "'method of pictorial
`
`representation of space related data' comprising: 'input medium (Shimada, figure 2); a plurality
`
`of spatially distributed data sources (Shimada, figure 1); and one device for determining the
`
`representation (Shimada, figure 23).'" The Examiner noted that although
`
`GOOGLE EXHIBIT 1005, Page 2 of 19
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`t-13416
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`Shimada does not explicitly teach 'selectable direction of view' as claimed . . .
`'direction of view' is a well known factor for displaying the retrieved object (Iwamura,
`figure 23). Thus, it would have been obvious to a person of ordinary skill in the art at the time
`the invention was made, in view of the teaching of Iwamura, to
`configure Shimada's system
`as claimed.
`
`It is respectfully submitted that applicants invention, as defined in claims 35-37, as
`
`previously amended, exhibits novelty over Shimada in view of Iwamura.
`
`The Examiner references Shimada, figure 2 for the assertion that it teaches the claimed
`
`"input medium" of claim 35. Shimada's specification at column 3, lines 9-15 describing figure
`
`2 states, "204 denotes a keyboard, numerals 205 and 206 denote, respectively, a tablet and a stylus
`
`for designating locations subjected to editing, and a numeral 207 denotes a drawing data input
`
`device for fetching the drawing or map data in terms of image data for vector analysis to derive
`
`coordinate data." Applicants specification at page 33, lines 14-20 describes the "input medium"
`
`as comprised of a "three-dimensional track ball in conjunction with a space-mouse with six
`
`degrees of freedom, in order to be able to alter both the location and direction of view of the
`
`observer, Automatic positioning-fixing systems can also be considered as further input media,
`
`such as are used in navigation aids for motor vehicles or aircraft." Applicants respectflilly submit
`
`that the Examiner's comparison of Applicants input medium of claim 35 and Shimada's figure
`
`2 is misplaced. Applicants input medium functions to enter in the location and/or the direction
`
`of view of the observer. However, the devices depicted in figure 2 of Shimada are intended for
`
`"fetching the drawing or map data. . . to derive coordinate data. Shimada is only concerned with
`
`the display of 2-dimensional geographical data, i.e. maps, without taking into account the position
`
`and view of the observer. Thus, Shimada does not teach the method of this application which is
`
`mainly concerned with organization of data with respect to an observer.
`
`GOOGLE EXHIBIT 1005, Page 3 of 19
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`1-13416
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`To the contrary, Iwamura is concerned with the graphic representation of objects
`
`depending on the position and view of the observer (see fig. 2A-2C). Further, Iwamura discloses
`
`distributed memories and computers, connected via a network used to transfer data from the
`
`storage medium to remote computers for display. It further discloses the selection of view by a
`
`mouse, a glove, a head-mounted binocular display, etc.
`
`However, Iwamura is concemed with displaying map-like 2-dimensional data and 3-
`
`dimensional object representation in the same window. For this it discloses a parallelepiped
`
`window mechanism for manipulating a virtual 3-dimensional window. Such mechanism is not
`
`mentioned or claimed in the present application.
`
`Iwamura is completely silent on the way to store, retrieve and assemble the data. Further,
`
`Iwamura fails to mention the claimed method for handling large amounts of data.
`
`The Examiner claimed that in a general Shimada case of 3-D display, the "direction of
`
`view"is a known factor for displaying the retrieved object (Iwamura, Fig.23). The Examiner
`
`further stated it would have been obvious to a person of ordinary skill in the art at the time the
`
`invention was made, in view of the teachings of Iwamura, to configure Shimada's system as
`
`claimed.
`
`Applicants respectfully submit that the Examiner's suggestion that the combination of
`
`Shimada and Iwamura as teaching applicants invention is misplaced. The Examiner concedes in
`
`the Office Action that Shimada fails to teach applicants claimed "selectable direction of view."
`
`There is no suggestion or incentive for the Examiner to combine the cited references. Even if
`
`proper, the combination of references does not result in the claimed invention. Obviousness
`
`cannot be established by combining the teachings of prior art to produce the claimed invention,
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`GOOGLE EXHIBIT 1005, Page 4 of 19
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`1- 1 3416
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`absent some teaching or suggestion supporting the combination. In light of the above discussion,
`
`it would not have been obvious to a person of ordinary skill in the art at the time the invention
`
`was made, in view of the teachings of Iwamura, to configure Shimada's system as claimed.
`
`TheExaminerinterpretsFig.lofShimadaasshowinea
`
`datasources.However,Fig.1disclosesa@,whichareallstoredinthe
`
`single file storage unit of Fig. 2a. Figure I of Shimada merely shows how data are divided into
`
`pages to be stored (col. 4, lines 1-2). It does not show, either explicitly or implicitly, that the data
`
`is stored in a plurality of spatially distributed data sources like the present invention.
`
`The present invention utilizes the spatially distributed data sources to call up, store and./or
`
`generate space-related data. The data sources include data memories and/or other data sources
`
`which call up and/or generate space-related data. This method differs from Shimada by
`
`providing the capability of a database not limited by the size of the central data memory.
`
`Therefbre, the amount of available data is not limited and can be extended at will. The present
`
`invention further differs from Shimada in that the servicing and updating of the database can be
`
`effected in a distributed manner and preferably in the vicinity of the spatial area.
`
`The Examiner has also claimed that figure 23 of Shimada teaches "one device for
`
`determining the representation." Figure 23 shows only the process of combining and dividing the
`
`pages of one map, which is completely different from the present invention. The present
`
`application is not at all concemed with the reassembly of pages or sections, it is suffrcient if the
`
`pages or sections fit together when they appear at their designated location. This invention is
`
`concerned with managing a practically infinite number of data, which are stored on different
`
`computer systems connected though a network and with retrieving/transferring the minimum
`
`GOOGLE EXHIBIT 1005, Page 5 of 19
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`1-13416
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`number of data necessary to provide a representation of the object with sufficient screen
`
`resolution in any part of the screen.
`
`The difference between Shimada and the present invention is further demonstrated by Fig.
`
`8 which depicts an explicit page list with direct access to the coordinates of the data, which with
`
`large maps, e.g. maps of the whole earth, becomes unmanageable in the central storage unit (main
`
`memory). In the present invention each part, i.e. section, of the represented data is loaded only
`
`in the topographical resolution to achieve suffrcient screen detail. Thus, not all available data of
`
`a section is loaded into main memory thereby reducing the size of transmitted data and the size
`
`of the main memory without the need for any "page/section."
`
`The Examiner rejected claims 36 and 37 arguing their subject matter is taught by Fig.26
`
`of Iwamura. Claims 36 and 37 each depend on claim 35, either directly or indirectly, and contain
`
`all of the limitations thereof. Therefore, claims 36 and 37 are also patentable over Shimada,
`
`Moreover, claim 36 claims an input medium for entering the location and/or the direction
`
`of view of the virtual observer. This medium may consist of a keyboard, a graphic tablet, a space
`
`mouse, a 3-dimensional track ball, a virtual camera or a model of the object observed. In contrast,
`
`Fig. 26 of Iwamura shows a 3-dimensional window management table. The table stores the
`
`coordinate values of active windows to ensure that the most recently opened window is not
`
`overlapped by an older window (col. 17, lines 14-52). The table neither explicitly or implicitly
`
`addresses the method of entrlz of the location or the direction of view of the virtual observer as
`
`claim 36 teaches. Accordingly, claim 36 is patentable for this additional reason.
`
`The Examiner similarly rejected claim 37 arguing its subject matter is also taught by Fig.
`
`26 of Iwamura. However, Fig, 26 completely fails to mention the use of an asynchronous
`
`GOOGLE EXHIBIT 1005, Page 6 of 19
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`1-13416
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`transmission protocal for the data transmission network taught by claim 37. Accordingly, claim
`
`37 is patentable for this additional reason.
`
`The Examiner's rejection of claims 1-34 "[d]ue to [their] similarity . . . to claims 35-37
`
`. . . under a similar reason" will now be addressed.
`
`Claim 1 of the applicants invention teaches a method to store, retrieve and display space
`
`related data of a selectable object with a preset image resolution. To obtain this resolution, data
`
`of the object are loaded in a basic topographical resolution and displayed. Subsequently, the field
`
`of view is divided into sections. Each section displays parts of the object with different distances
`
`from the observer. This requires that each section possess data on a different topographic scale.
`
`The individual sections are checked to ensure they each are displayed in sufficient screen
`
`resolution. If the resolution is not sufficient, data or higher topographical resolution of this
`
`section are requested, transferred and displayed. This step is repeated for ever smaller sections.
`
`The result of the repetition of the request, transfer and display of data produces the object with
`
`the required screen resolution.
`
`Due to the amount of data required, the highest resolution of an object cannot be stored
`
`centrally. Therefore, these data are locally stored in a distributed system and only transferred
`
`upon request.
`
`Shimada discloses a method for splitting and reassembling given maps, which are 2-
`
`dimensional geographic data, into pages. In other words, Shimada breaks down large maps into
`
`chunks for easier storage and retrieval. Shimada is not at all concerned with the screen resolution.
`
`Nor is Shimada concerned with the handling of data volumes. This fact is illustrated by
`
`Shimada's Fig.2a which shows all data is stored in the central storage unit. Shimada also fails
`
`GOOGLE EXHIBIT 1005, Page 7 of 19
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`t-t3416
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`to teach the use of a network to transfer data as in the present invention. Lastly, Shimada, unlike
`
`the present invention, does not take into account the position and view of the observer.
`
`Accordingly, claim 1 is patentable for this reason.
`
`Although Iwamura discloses the representation of objects with respect to the position and
`
`view of the observer, distributed memories and computers connected via a network, and a
`
`method to select the observer's view, Iwamura is completely silent on the way to store, retrieve
`
`and assemble the data. Accordingly, claim i is patentable for this additional reason.
`
`Claims 2-34 each depend on claim 1, either directly or indirectly, and contain all of the
`
`limitations thereof. Therefore, claims 2-34 Ne also patentable over Shimada in view of Iwamura.
`
`For the foregoing reasons, applicants submit that the present invention is patentable over
`
`the combined teachings of Shimada in view of Iwamura. There is no suggestion or incentive for
`
`the Examiner to combine the cited references. Even if proper, the combination of references does
`
`not result in the claimed invention. The Examiner has the burden of demonstrating that
`
`applicants claimed invention is prima facie obvious. Obviousness cannot be established by
`
`combining the teachings of the prior art to produce the claimed invention, absent some teaching
`
`or suggestion supporting the combination. The mere fact that the prior art may be modified does
`
`not make the modification obvious unless the prior art suggested the desirability of the
`
`modification. In re Fritch, 23 U.S.P.Q.2d 1780, 1783-1784 (CAFC, 1992). Applicants
`
`respectfully submit that the present invention as defined in the claims is patentable over the
`
`teachings of Shimada in view of Iwamura.
`
`GOOGLE EXHIBIT 1005, Page 8 of 19
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`t-13416
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`The prior art cited, but not relied upon, by the Examiner in the rejection has been studied
`
`and is not considered to be any more pertinent than the art relied upon by the Examiner.
`
`In view ofthe previous amendments to the claims and the above arguments, it is submitted
`
`that the claims of record now properly define applicants invention and distinguish the same over
`
`the prior art ofrecord. Therefore, the application appears to be in condition for allowance.
`
`Accordingly, an early Notice of Allowance is respectfully requested.
`
`Should the Examiner wish to modifu any ofthe language of the claims, applicants attorney
`
`suggests a telephone interview in order to expedite the
`
`ution of the application.
`
`Phillip S. Oberlin
`Registration No. 19,066
`
`ATTORNEYS:
`
`MARSHALL & MELHORN
`Four SeaGate, Eighth Floor
`Toledo, Ohio 43604
`(4t9) 24e-7t00
`
`GOOGLE EXHIBIT 1005, Page 9 of 19
`
`
`
`"Express Mail" Mailing Label Number EL42464l0l3US Date of
`Deposit January 20. 2000 I hereby certify that this paper or fee is
`being deposited with the United States Postal Service "Express Mail
`Post Office to Addressee" service under 37 CFR 1.10 on the date
`indicated above and is addressed to the Box CPA, Assistant
`Commissioner for Patents, Washington, D.C. 20231
`
`Heidi M. Walters
`(typed or printed name)
`r:iL.,"'w [\1 \*.,th ,.. r,
`(signature)
`
`t .r
`
`IN THE LN{ITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Applicatiori of:
`Pavel Mayer et al.
`
`Filed: December 17, 1996
`Serial No.: 08/767.829
`
`Examiner: P. Nguyen
`
`Group Artunit2772
`
`For: METHOD AND DEVICE FOR
`PICTORIAL REPRESENTATION]
`OF SPACE-RELATED DATA ]
`
`Attorney Docket l-13416
`
`January 20,2000
`
`PRELIMINARY AMENDMENT
`
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`Dear Horrorable Sir:
`
`Prior to the first Office Action, please amend the CPA application being filed concurrently
`
`lierewith as follows:
`
`\,
`\\
`Cancel Clairns l-37
`
`Add nerv Clairns 38-79 as follows:
`
`GOOGLE EXHIBIT 1005, Page 10 of 19
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`1-13416
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`l,
`\
`
`a method of providing a pictorial representation of space-related data of a selectable
`
`object, the representation corresponding to the view of the object by an observer with a selectable
`
`location and a selectable direction of view comprising:
`
`(a) providing a plurality of spatially distributed data sources for storing space-related
`
`data;
`
`(b) determining a field of view including the area of the object to be represented through
`
`the selection of the distance of the observer to the object and the angle of view of the observer to
`
`the object;
`
`(c) requesting data for the field of view from at least one of the plurality of spatially
`
`clistributed clata sources:
`
`(d) centrall)/ storing the data fbr the field of view;
`
`(e) representing the data for the field of view in a pictorial representation having one or
`
`more sections;
`
`(f) dividing each of the one or more sections having image resolutions below a desired
`
`image resolution into a plurality of smaller sections, requesting higher resolution space related
`
`data for each of the smaller sections from at least one of the plurality of spatially distributed data
`
`sources, centrally storing the higher resolution space related data, and representing the data for
`
`the freld of view in a pictorial representation; and
`
`(g) repeating step (f), dividing the sections into smaller sections, until every section has
`
`the desired image resolution or no higher image resolution data is available.
`
`GOOGLE EXHIBIT 1005, Page 11 of 19
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`1 -13416
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`z,
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`3A- lne method of pictorial representation defined in Claim \further inclucling altering
`
`the selectable location and perfbrming steps (b) through (g).
`
`4'
`./
`}0r fne method of pictorial representation defined in Claim\further including altering
`
`the selectable direction of the view and performing steps (b) through (g),
`
`c,
`bL 1n. method of pictorial representation defined in Claim\wherein step (f) further
`
`I
`
`includes requesting data of a uniform resolution for each of the smaller sections.
`
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`fn" method of pictorial representation defined in Claim\ wherein steps (c) and (f)
`
`further include requesting data not already centrally stored from only one of the spatially
`
`distributed data sources.
`
`B.
`\
`includes showing only the centrally stored data of each section with the highest spatial density.
`
`.l
`fn. method of pictorial representation defined in Claim\ wherein step (f) further
`
`.9.
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`1f',. method of pictorial representation defined in Claim\wherein step (f) further
`\
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`includes effecting the representation of the data in an optional pre-set form of representation.
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`GOOGLE EXHIBIT 1005, Page 12 of 19
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`1-13416
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`lb,
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`TS ttie method of pictorial representation defined in Claim }& further including
`removir1g the data of a section from the central store when the section passes out of the field of
`
`view due to an alteration i1the location or of the angle of the view.
`
`1\.
`tEffr. merhocl of pictorial representation defined in Claim \ further including
`
`I
`
`perntanently centrally storing at least one fr-rll set of space-related data with a iow spatial
`
`resolutiot-t.
`
`lz,
`\fne methocl of pictor"ial representation defined in Claim \
`showing the regions of the object located with respect to the observer behind non-transparent
`
`further including not
`
`.l
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`
`areas ofthe object,
`
`13.
`ff,. method of pictorial representation defined in Claim )& wherein step (f)
`\
`comprises diviciing each of the one or more sections using a model of the binary tree'
`
`.l
`
`ri.
`}\
`
`The method of pictorial representation defined in Clai-$g,.*herein step (f)
`
`comprises dividing each of the one or more sections using a model of the quadrant tree.
`
`6t
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`
`method of pictorial representation defined in Claim )8* wherein step (l;
`
`comprises dividing the sections using a model of the octant tree.
`
`i
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`ii
`
`GOOGLE EXHIBIT 1005, Page 13 of 19
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`t-13416
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`fn. method of pictorial representation defined in Claim\ further including using
`\
`an adaptive sub-dir,ision model with a plurality of models used next to one another for sub-
`
`dividing the field of view into smaller sections.
`
`trl
`\
`present as pixel graphics and/or as vector graphics and/or in tabular form.
`
`ff'r" method of pictorial representation defined in Claim\ wherein the data are
`
`It.
`.l
`ff-,. metl-rod of pictorial representation defined in Claim\\ wherein the object is a
`\
`
`heavenly'bocl1,.
`
`47,
`..1
`\
`fng methocl of pictorial representation defined in Claim\wherein the object is the
`
`earth.
`
`t
`
`,n. method of pictorial representation defined in Claim*. wherein steps (e) and (f)
`
`further include representing the data with a polygonal grid model.
`
`.'-3q
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`\fne method of pictorial representation defined in Claim }8" wherein steps (e) and (f1
`further include representing the data with a three-dimensional geometrical model of the
`
`topography of the objects, the spatial relationship of the data being given by the provision of
`
`three co-ordinates on the geometrical model.
`
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`GOOGLE EXHIBIT 1005, Page 14 of 19
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`\X ffr. method of pictorial representation defined in Claim\ wherein step (f)
`
`comprises dividing the sections using a model of the octant tree.
`
`lb
`The method of pictorial representation defined in Claim\ wherein steps (e) and (f1
`
`ll.
`\
`further include representating the data with a two-dimensional polygonal geometrical model of
`
`the topography of the object, the spatial relationship of the data being given by the provision of
`
`two co-ordinates on the polygonal geometrical model.
`
`aq
`'!)
`\
`The method of pictorial representation defined in Claim \wherein height
`information is represented as color vertices on the two-dimensional polygonal geometrical
`
`model.
`
`el'
`r?
`fi-,. method of pictorial representation defined in Claim Xl wherein an adaptive
`\
`
`topographical gr:id model is used, the spatial distance between two grid lines becoming smaller as
`
`the topographical altitude becomes greater.
`
`Ja
`\(
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`ffr. rnethod of pictorial representation defined in Claim\ wherein step (f) further
`
`inch-rcles dividing each of the one or more sections using a model of the quadrant tree.
`
`Bt ., ^
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`GOOGLE EXHIBIT 1005, Page 15 of 19
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`'6:. fne method of pictorial representation defined in Claimh wherein step (f) further
`
`inclr"rdes dividing each of the one ormore sections using an adaptive sub-division model such
`
`that the sr-rbdivision merges into a binary tree at the poles.
`
`aY.
`tl
`ff-r. method of pictorial representation defined in Claim\wherein in the two-
`fl
`
`dimensional polygonal grid model, spatial data are shown on a plurality of different two-
`
`dimensional layers.
`
`B]^
`C-er.tt
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`fn" method of pictorial representation defined in Claim\ wherein the
`\
`
`representation in steps (e) and (f) is in the form of a globe.
`
`|}
`aa
`\fne method of pictorial representation defined in Claim}3, wherein the
`
`representation in steps (e) and (f) is in the form of cartographic form of representation.
`
`L
`3.
`b'( The method of pictorial representation defined in Claim39rfurther including
`
`determining the data and/or the co-cordinates of the data in terms of a new co-ordinate system.
`
`(v{C\ Thc nre'thod of pictorial representation defined in Claim\ further including
`
`detenninirrg the data and/or the co-cordinates of the data in terms of a new co-ordinate system.
`
`GOOGLE EXHIBIT 1005, Page 16 of 19
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`31.
`I
`b& The method of pictorial representation defined in Claim\ wherein the space-
`
`related data include CAD models.
`
`3?.
`b\ fn. method of pictorial representation defined in ClaimlLfurther including
`
`,
`
`inserting apimated objects into the pictorial representation.
`
`33.
`.l
`{fn. method of pictorial representation defined in Claim\further including
`inserting display tables into the pictorial representation.
`
`Bt
`CDl,Tf
`
`3t
`_l
`zur fne method of pictorial representation defined in Claim\ further including
`
`inserting information ancl/or directly generated image material into the representation.
`
`3<
`-r
`'{ fn. method of pictorial representation defined in Clairil\wherein the directly
`
`generated image material includes camera shots.
`
`3c.
`I
`X fn. method of pictorial representation defined in Claim\wherein the space related
`
`data are provided with references to further spatial data.
`
`32
`}4-
`
`The method of pictorial representation defined in Claim{ wherein the space related
`
`data are provided with references to thematically adjacent data.
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`GOOGLE EXHIBIT 1005, Page 17 of 19
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`
`
`l-t3416
`
`3qt
`fne method of pictorial representation defined in Claim\wherein the space related
`\
`data are provided with references to data of the same area with another resolution.
`
`3?k
`
`The method of pictorial representation defined in Claimkfurther including
`
`determining a probability for the regions surrounding the field of view that the regions will pass
`
`into the fleld of viei.v when there is an alteration in the location or of the angle of view of the
`
`observer.
`
`10,
`3r
`3l
`fn. method of pictorial representation defined in claim 76 further including
`\
`Ot}laO reluesting and centrally storing the data of the areas with the highest probability.
`\r.
`)a. ff,. method of pictorial representation defined in claim \ wherein steps (c) and (1)
`further include transmitting data asynchronously.
`
`,
`
`(q.
`\
`fne rnethod of pictorial representation defined in claim \wherein steps (e) and (f)
`
`r
`
`further inclr-rde showing the data on a screen.
`
`REMARKS
`
`Applicant has canceled claims l-37 , and added new claims 38-79. Favorable
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`consicleration of these claims is respectfully requested,
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`GOOGLE EXHIBIT 1005, Page 18 of 19
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`
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`r-13416
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`Regarding the cited references, Shimada shows a plurality of different maps in layers A-D
`
`corresponding to the same district and teaches dealing with the correspondence between pages
`
`having different scales. Shimada does not teach the method of continually dividing and
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`subdividing sections of the pictorial representaion having unacceptable resolution into smaller
`
`ar-rd smaller sections, recluesting higher resolution space related data for each of these smaller
`
`sections and repeating this process until every section has an acceptable resolution or no more
`
`higlier resolution data is available. Shimada explicitly states in claim I that "each layer
`
`comprises the complete data of a different map".
`
`While Shimada teaches a plurality of spatialy distributed data, Shimada does not teach
`
`using a plurality of spatialy distributed data sources for storing the space-related data. Fig. 2a of
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`Shimada shows only one single file storage unit for all the maps and does not show a network
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`communicating between spatialy distributed data sources.
`
`For these reasons, newly added independent claim 38, and claims 39-Tgdepending
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`therefiom, are patentable over the cited references. Accordingly, it is believed that the
`
`application is in condition for allowance,
`
`Respectfully submitted,
`MARSHALL & MELHORN
`
`Patrick D. Floyd
`Registration No. 39,67 I
`
`ATTORNEYS
`MARSI]ALL & MELHORN
`Four SeaGate/Eighth Floor
`Toledo, Ohio 43604
`(419) 249-7132
`
`GOOGLE EXHIBIT 1005, Page 19 of 19
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`