REMARKS
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`In the latest Office Action, the Examiner rejected claims 1-4 and 9-11 under the
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`judicially created doctrine of obviousness-type double patenting as being unpatentable
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`over claim 20 of US. Patent No. 6,650,622. Claims 1-5, 11, 13 and 14 were rejected
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`under 35 USC 102(e) as being anticipated by De Bruycker et al (US. Patent No.
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`6,272,219). Claim 6 was rejected as being obvious under 35 USC 103(a) over De
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`Bruycker, while claims 7, 8 and 12 were rejected as being obvious over the combination
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`of De Bruycker in view of Williams (US. Patent No. 5,216,704). For the reasons set
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`forth below, reconsideration of this application is respectfully requested.
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`Double Patenting
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`While Applicant makes no admission about the obviousness of the claims, a
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`Terminal Disclaimer is being submitted herewith to render this objection moot.
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`Claim Reiections — 35 USC S 102
`While De Bruycker can loosely be characterized as a network, it is not the type of
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`network that includes dedicated cables to each piece of equipment on the network. De
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`Bruycker is a telephone communication system in which a telephone company location
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`100 communicates with a customer premise 200 through a complex switching network,
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`typically referred to as a PSTN (which stands for Public Switched Telephone Network).
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`Page 8 of 12
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`Chrimar Systems, Inc.
`Exhibit 2080-1
`IPR2016-00574 USPN 8,902,760
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`Wikipedia explains the operation of a PSTN as follows:
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`Routing in the PSTN
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`From Wikipedia, the free encyclopedia
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`Jump to: navigation, search
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`In the context ofthe public switched telephone network, routing is the process by which
`telephone calls are routed around the telephone network. Telephone exchanges are connected
`together with trunks. Each call that is to be routed contains a destination number that has two
`parts, a prefix which generally identifies the geographical location of the destination telephone,
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`and a number unique within that prefix that determines the precise destination.
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`The exchange uses pre-computed routing tables, which are generated by batch processing at
`central locations based on the known topology of the network, the numbering plan, and analysis
`of traffic data. These are then downloaded to telephone exchanges at intervals. There may be
`several alternative routes to any given destination, and the exchange can select dynamically
`between these in the event of link failure or congestion.
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`Because of the hierarchical nature of the numbering plan, and its geographical basis, most calls
`can be routed based only on their prefix. Exceptions include intelligent network services with
`non-geoggaphical numbers, such as toll-free or freephone calling.
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`Routing in circuit-switched networks involves creating a path from one customer to another for
`the duration of each call. Routing decisions are an important part of this process as they
`determine which channels or circuits are used to connect the customers for the duration of the
`call. In a PSTN exchange, routing is typically performed using a routing table that contains the
`pre-defined routes for a connection. In such a system, alternative routes exist, which are
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`specified in the routing tables [1].
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`In determining routing plans, special attention is paid for example to ensure that two routes do
`not mutually overflow to each other, otherwise congestion will cause a destination to be
`completely blocked.
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`According to Braess' paradox, the addition of a new, shorter, and lower cost route can lead to an
`increase overall congestion [1, 2]. The network planner must take this into account when
`designing routing paths.
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`One approach to routing involves the use of Dynamic Alternative Routing (DAR) [l]. DAR
`makes use of the distributed nature of a telecommunications network and its inherent
`randomness to dynamically determine optimal routing paths. This method generates a
`distributed, random, parallel computing platform that minimises congestion across the network,
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`Chrimar Systems, Inc.
`Exhibit 2080-2
`IPR2016-00574 USPN 8,902,760
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`

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`and is able to adapt to take changing traffic patterns and demands into account [1]. (emphasis
`added)
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`Of particular importance is the statement that there may be “several alternative routes to
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`a given destination". Thus, there is no one-to—one or dedicated physical cable wires that
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`connect the telephone company location 100 to the customer premise 200. Since there
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`are no dedicated cable wires, Applicant’s technique for identifying equipment on a
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`network by varying the electrical characteristics across the wires cannot be
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`implemented in De Bruycker. This is because there simply are no dedicated wires in a
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`telephone switching network.
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`Claim 1 has been amended for clarification purposes and should not be
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`considered as narrowing the scope of the invention. Claim 1 clearly now calls for each
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`piece of equipment to be connected to the central module by its own cable.
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`For
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`example, claim 1 calls for “a first cable having wires therein connected between the
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`central module and the first piece of equipment". Claim 1 goes on to recite "a second
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`cable having wires therein connected between the central module and the second piece
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`of equipment.” Claim 1 further recites that a remote module is utilized in generating “a
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`variable impedance across at least a pair of wires in the first cable to define a first multi-
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`bit signal associated with a first piece of equipment."
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`In the preferred embodiment this
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`multi-bit signal provides an identification signal uniquely associated with the first piece
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`of equipment. A second piece of equipment can also be uniquely identified by "a
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`second remote module utilized in generating a variable impedance across at least a pair
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`of wires in the second cable to define a second multi-bit signal associated with the
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`second piece of equipment". Thus, communication between the central module and
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`Chrimar Systems, Inc.
`Exhibit 2080-3
`IPR2016-00574 USPN 8,902,760
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`0
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`various pieces of equipment on the network can be implemented in an eloquently
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`simple but effective manner.
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`This structure and mode of operation is simply not
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`disclosed or suggested by De Bruycker. Thus, the § 102 rejection should be removed.
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`Claim Reiections — 35 USC § 103
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`Claims 6-8 and 12 depend from claim 1. Thus, they are distinguishable at least
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`for the reasons set forth above in connection with claim 1.
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`In addition, the Examiner
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`appears to be using an impermissible hindsight approach in which to reject
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`these
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`claims. For example, claim 6 not only calls for the central module to be able to identify
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`the existence of the piece of equipment, it also calls for the central module to be able to
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`identify the location of the equipment without power being applied to the equipment.
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`This is not disclosed or suggested by De Bruycker. Claim 7 calls for the power
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`demodulator
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`in the remote module to demodulate the power signal
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`“to detect
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`information sent from the central module”. Claim 7 further recites that “information can
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`be bi-directionally transmitted between the central module and the remote modules.”
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`The additional reference to Williams (US. Patent No. 5,216,704) fails to disclose this
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`structure or mode of operation. Williams’ power sink 54 cannot be reasonably
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`construed as a “power modulator". Even if it is a power demodulator it does not function
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`in the manner recited in claim 7. Claim 8 further calls for the central module to block
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`network information from being communicated to a piece of equipment that does not
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`send the proper signal backto the central module. This recitation is not remotely
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`suggested in any of the references cited by the Examiner.
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`Serial No. 10/668,708
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`-
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`Page 11 of 12
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`Chrimar Systems, Inc.
`Exhibit 2080-4
`IPR2016-00574 USPN 8,902,760
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`

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`Request for Interview
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`It is submitted that this amendment and response should place this application in
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`condition for allowance and such action is respectfully requested.
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`In the event that the
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`Examiner does not issue a Notice of Allowance in the next communication, Applicant
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`requests an interview to discuss this application before any other type of communication
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`is issued.
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`For the foregoing reasons, it is believed that this application is now in condition
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`for allowance and such action is respectfully requested.
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`Respectfully submitted,
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`By:
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`[firsts ”Mfifiéfifi'fl V
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`Dated:
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`75/ 5, 2008
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`HARNESS, DICKEY & PIERCE, P.L.C.
`PO. Box 828
`Bloomfield Hills, Michigan 48303
`(248) 641-1600
`‘
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`GGS/slm
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`Serial No. 10/668,708
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`Page 12 of 12
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`Chrimar Systems, Inc.
`Exhibit 2080-5
`IPR2016-00574 USPN 8,902,760