IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`PATENT
`
`Application No.:
`
`90/009,513
`
`Filing Date:
`
`September 24, 2009
`
`Applicant
`
`Patent No. 7,457,250
`
`Group Art Unit:
`
`3992
`
`Examiner:
`
`Eric B. Kiss
`
`Title:
`
`COMMUNICATING
`FOR
`SYSTEM
`ELECTRONIC EQUIPMENT
`
`\NITH
`
`Attorney Docket
`
`9919-000002/RXF
`
`Mail Stop Ex Parle Reexam
`Central Reexamination Unit
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`Sir:
`
`RESPONSE
`
`In response to the Office Action mailed April 20, 2010, please consider the
`
`remarks set forth below.
`
`A listing of the Patent Claims begin on page 2 of this paper.
`
`Remarks begin on page 22 of this paper.
`
`Chrimar Systems, Inc.
`Exhibit 2081-1
`IPR2016-00574 USPN 8,902,760
`
`
`
`PATENT
`
`Application No.:
`
`90/009,513
`
`Filing Date:
`
`September 24, 2009
`
`Applicant
`
`Patent No. 7,457,250
`
`Group Art Unit:
`
`3992
`
`Examiner:
`
`Eric B. Kiss
`
`Title:
`
`COMMUNICATING
`FOR
`SYSTEM
`ELECTRONIC EQUIPMENT
`
`\NITH
`
`Attorney Docket
`
`9919-000002/RXF
`
`Mail Stop Ex Parle Reexam
`Central Reexamination Unit
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`Sir:
`
`RESPONSE
`
`In response to the Office Action mailed April 20, 2010, please consider the
`
`remarks set forth below.
`
`A listing of the Patent Claims begin on page 2 of this paper.
`
`Remarks begin on page 22 of this paper.
`
`Chrimar Systems, Inc.
`Exhibit 2081-1
`IPR2016-00574 USPN 8,902,760
`
`
`
`THE CLAIMS
`
`The following is a listing of the claims in U,S. Patent No. 7,457,250. They are
`
`not being amended.
`
`LISTING OF CLAIMS
`
`1.
`
`(Original) A system for communicating information on a network
`
`having pieces of electronic equipment that connect to the network by cables having a
`
`plurafity of wires therein, said system comprising:
`
`a central module having at least one power source;
`
`a first piece of equipment;
`
`a first cable having wires therein connected between the central module and
`
`the first piece of equipment;
`
`a first remote module utilized in conjunction with the central module to alter a
`
`flow of current within at least a pair of wires in the first cable, the altered current flow
`
`communicating information about the first piece of equipment to the central module
`
`while the first piece of equipment is physically connected to the network via the first
`
`cable;
`
`a second piece of equipment;
`
`a second cable having wires therein connected between the central module
`
`and the second piece of equipment; and
`
`a second remote module utilized in conjunction with the central module to
`
`alter a flow of current within at least a pair of wires in the second cable, the altered
`
`current flow communicating information about the second piece of equipment to the
`
`central module while the second piece of equipment is physically connected to the
`
`network via the second cable.
`
`Serial No. 90/009,513
`
`Page 2 of 99
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`Chrimar Systems, Inc.
`Exhibit 2081-2
`IPR2016-00574 USPN 8,902,760
`
`
`
`REMARKS
`
`The Examiner is respectfully requested to reconsider and withdraw the
`
`rejections in view of the amendments and remarks contained herein.
`
`REJECTION UNDER 35 U.S.C. § 103
`
`Claims 1, 2, 5, 13, 15, 20-32, 34, 36, 41, 42, 45-47, 49, 50, 53, 54, 56-68, 70,
`
`72, 77, 78,81-83,85,86,89,90,92-104, 106, 108, 113, 114, 117~119, 121,and 122
`
`stand rejected under 35 U.S.C. § 103(a) as being unpatentable over WO 96/23377
`
`A 1 published August 1, 1996 ("lntecom")
`
`in view of IBM Technical Disclosure
`
`Bulletin, No. 01-78, pp. 3164-3165 published January 1978 ("IBM TDB").
`
`Claims 43, 79, and 115 are rejected under 35 U.S.C. § 103(a) as being
`
`unpatentable over lntecom in view of IBM TDB and further in view of U.S. Patent No.
`
`6,473,608 ("Lehr").
`
`These rejections are respectfully traversed. The Examiner is requested to
`
`reconsider his rejection and issue an exparte reexamination certificate confirming the
`
`patentability of the claims in U.S. Patent No. 7,457, 250 (the "'250 Patent").
`
`PATENT OWNER'S INTERVIEW STATEMENT
`
`The patent owner has filed herewith its Patent Owner's Statement of Interview
`
`on May 12, 2010. This Statement was filed by way of a separate paper at the
`
`request of the Examiner Kiss.
`
`ARGUMENTS
`
`Claim 1
`
`In his rejection, the Examiner states:
`
`Serial No. 901009,513
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`Page 22 of 99
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`Chrimar Systems, Inc.
`Exhibit 2081-3
`IPR2016-00574 USPN 8,902,760
`
`
`
`Regarding claim 1, lntecom discloses:
`
`A system for communicating information on a network having pieces of
`
`electronic equipment that connect to the network by cables having a plurality of wires
`
`therein (e.g., lntecom at Figs. 1 and 2), said system comprising:
`
`a central module having at least one power source (e.g., !ntecom at Fig. 2
`
`(power source 210 is in the central module); Page 35, line 27 - Page 36, line 20);
`
`a first piece of equipment (e.g., lntecom at Figs. 1 and 2 (showing various
`
`pieces of equipment));
`
`a first cable having wires therein connected between the central module and
`
`the first piece of equipment {e.g., lntecom at Figs. 1 and 2 (the Multimedia Hub is
`
`connected to the various pieces of equipment by the cable having wires (240,250) as
`
`shown in Fig. 2)};
`
`a second piece of equipment (e.g., lntecom at Fig 1; p. 37, lines 10-18
`
`(enabling phantom powering to many pieces of equipment)); and
`
`a second cable having wires therein connected between the central module
`
`and the second piece of equipment (e.g., lntecom at Fig. 1; p. 37, lines 10-18 ("In an
`
`overall LAN, many pieces of equipment, each with its own third and fourth
`
`transformers 270, 280, can take power as well as data from the bus.")).
`
`Although intecom discloses remote equipment reasonably interpreted as
`
`comprising "remote modules," that separate the DC bias of the power subsystem
`
`from the data inputs on the equipment and provide further conditioning of the data
`
`signals before they are introduced to the equipment (Jntecom at Fig. 2; p. 38, lines 1-
`
`11 ), I ntecom fails to expressly disclose:
`
`a [firstlsecond] remote module utilized in conjunction with the central module
`
`to alter a flow of current within at least a pair of wires in the ffirstlsecondJ piece of
`
`Serial No. 90/009,513
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`Page 23 of 99
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`Chrimar Systems, Inc.
`Exhibit 2081-4
`IPR2016-00574 USPN 8,902,760
`
`
`
`equipment to the central module while the [first/second] piece of equipment is
`
`physically connected to the network via the [first/second] cable.
`
`However, fBM TDB teaches, in an analogous remote powering system, a
`
`piece of equipment connected to a central module (containing a remote power
`
`source) via a cable (a transmission line) and a remote module utilized in conjunction
`
`with the remote power source to alter a flow of current, particularly by an amount
`
`delta lo, within a pair of wires, the altered current flow communicating information
`
`about the piece of equipment to the central module (containing the remote power
`
`source), particularly the increased current consumption and thus the requirement for
`
`an increased voltage supply, while the piece of equipment is physically connected to
`
`the central module via a cable.
`
`It would have been obvious to one of ordinary skill in the art at the time the
`
`invention was made to modify the remote powering system described by lntecom
`
`with the remote power switching capabilities as taught by IBM TDB in order to gain
`
`the benefits of being able to switch from a low-voltage stand-by mode to a higher(cid:173)
`
`voltage active mode as power requirements and load conditions change in a remote
`
`powering environment such as that taught by lntecom.
`
`The Patent Owner's Contentions
`
`Claim 1 is set forth below:
`
`1. A system for communicating information on a network having pieces of
`
`electronic equipment that connect to the network by cables having a plurality of wires
`
`therein, said system comprising:
`
`a central module having at least one power source;
`
`a first piece of equipment;
`
`Serial No. 90/009,513
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`Page 24 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-5
`IPR2016-00574 USPN 8,902,760
`
`
`
`a first cable having wires therein connected between the central module and
`
`the first piece of equipment;
`
`a first remote module utilized in conjunction with the central module to alter a
`
`flow of current within at least a pair of wires in the first cable, the altered current flow
`
`communicating information about the first piece of equipment to the central module
`
`while the first piece of equipment is physically connected to the network via the first
`
`cable;
`
`a second piece of equipment;
`
`a second cable having wires therein connected between the central module
`
`and the second piece of equipment; and
`
`a second remote module utilized in conjunction with the central module to
`
`alter a flow of current within at least a pair of wires in the second cable, the altered
`
`current flow communicating information about the second piece of equipment to the
`
`central module while the second piece of equipment is physically connected to the
`
`network via the second cable.
`
`During the
`
`interview,
`
`the patent owner briefly explained some of the
`
`constraints empioyed by claimed subject matter, referring to the following sketch
`
`made at the interview:
`
`Serial No. 90/009,513
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`Page 25 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-6
`IPR2016-00574 USPN 8,902,760
`
`
`
`(j#Z
`
`According to claim 1, there is "a first cable having wires therein connected between
`
`the central module and the first piece of equipment" (0#1). Claim 1 also calls for "a
`
`second cable having wires therein connected between the central module and the
`
`second piece of equipment" (0#2). There is no current in one cable i.e. the cabling
`
`for 0#1, being shared with another object i.e. 0#2 (as noted in the circled area in the
`
`sketch). The claim also goes on to call for generating an altered current flow "within
`
`at least a pair of wires in the first cable", with this altered current flow serving to
`
`communicate ''information about the first piece of equipment to the central module
`
`while the first piece of equipment is physically connected to the network via the first
`
`cable".
`
`The claim further recites that an altered current flow is also generated in the
`
`second cable to communicate "information about the second piece of equipment to
`
`the central module while the second piece of equipment is physically connected to
`
`the network via the second cable".
`
`The lntecom reference fails to disclose this structure or mode of operation.
`
`Instead of separate or dedicated cabling for each piece of equipment, the lntecom
`
`Serial No. 90/009,513
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`Page 26 of 99
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`Chrimar Systems, Inc.
`Exhibit 2081-7
`IPR2016-00574 USPN 8,902,760
`
`
`
`reference employs a bus to which many pieces of equipment can be connected
`
`thereby sharing the current for one piece of equipment with another piece of
`
`equipment In his rejection, the Examiner refers to page 37 of lntecom which clearly
`
`states that "many pieces of equipment" ... "can take power as well as data from the
`
`bus".
`
`In other words, there is no first cable ... connected between the central
`
`module and the first piece of equipment and no second cable ... connected between
`
`the central module and the second piece of equipment in !ntecom, as recited in claim
`
`1.
`
`In contrast, many pieces of equipment can be connected to the same bus in
`
`lntecom such that current for one piece of equipment is shared with another piece of
`
`equipment. At the interview, the patent owner referred to the following sketch in his
`
`discussion of lntecom:
`
`·-~. ~--¥·, --- ·-~--r,.,,......,.,..·--~ ·-·--r-..
`l
`I
`1
`,;.,.
`P'i"<
`'
`
`0 !
`t i
`
`r r+~~;~~~r--------
`L~,__.. ......... / __ i---~-1
`J !
`I
`I.
`I
`I
`l-:r-l
`
`1 Y-·
`
`.
`
`I
`
`\
`
`1
`
`l
`
`1
`
`Since there are many pieces of equipment connected to lntecom's bus, lntecom fails
`
`to disclose, for example, how to distinguish one piece of equipment from another
`
`Serial No. 90/009,513
`
`Page 27 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-8
`IPR2016-00574 USPN 8,902,760
`
`
`
`piece of equipment using an altered current flow on the bus.
`
`In fact, it appears that
`
`this is not possible in lntecom. Therefore, lntecom does not teach how to use an
`
`altered current flow in wires in a first cable to communicate information about the first
`
`piece of equipment to a central module, and using an altered current flow within
`
`wires in the second cable to communicate information about the second piece of
`
`equipment via the second cable, in the manner called for in '250 patent Claim 1.
`
`The Examiner admits in his rejection that lntecom fails to expressly disclose:
`
`a [first/second] remote module utilized in conjunction with the central rnoduie
`
`to alter a flow of current within at least a pair of wires in the [first/second] piece of
`
`equipment to the central module while the [first/second] piece of equipment is
`
`physically connected to the network via the [first/second] cable.
`
`As noted above, it is the patent owner's position that lntecom fails to disclose
`
`more of the claimed recitations in claim 1 than admitted by the Examiner. Assuming,
`
`arguendo, that lntecom discloses all of the claim 1 limitations except as noted above,
`
`the Examiner's reliance on IBM TDB still fails to render claim 1 obvious. During the
`
`interview, the patent owner made reference to the following sketch about IBM TDB:
`
`Serial No. 90/009,513
`
`Page 28 of99
`
`Chrimar Systems, Inc.
`Exhibit 2081-9
`IPR2016-00574 USPN 8,902,760
`
`
`
`S1, S2, and S3 (and any loads or objects connected thereto) are all connected
`
`together. As a result, IBM TDB fails to teach how to relate information about a piece
`
`of equipment/object to an altered current flow. For example, IBM TDB states
`
`"whenever any one of these loads requires power, it generates a power-on request
`
`signal...". While this "power-on request signal" is characterized by an increased
`
`current within the wires of the shared transmission line, there is no teaching in IBM
`
`TDB as to how information about a load can be related to such an increased current.
`
`Distinguishing one piece of equipment from another is not important for the operation
`
`of IBM TDB since the power-on request signal from "any one of these loads" at any
`
`one of the terminals is sufficient to switch the power from 12V to 48V. There is
`
`simply no equivalent structure to the claim 1 limitations of a first cable connected
`
`between a central module and the first piece of equipment and a second cable
`
`connected between the central module and the second piece of equipment, with an
`
`Serial No. 90/009,513
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`Page 29 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-10
`IPR2016-00574 USPN 8,902,760
`
`
`
`altered current flow in the first cable communicating information about the first piece
`
`of equipment and,
`
`in addition, an altered current flow in the second cable
`
`communicating information about the second piece of equipment. The structure
`
`disclosed in IBM TDB simply cannot be used to related information about a piece of
`
`equipment/object to an altered current flow because there is no separate cabling for
`
`each terminal much less each piece of equipment.
`
`Even if the Examiner's proposed combination was proper, the proposed
`
`combination still would not read on the claimed recitations in patent claim 1.
`
`Moreover, the patent owner argues that the combination would not be proper.
`
`IBM
`
`TDB relates to a switchable power supply that provides 12V or 48V power over a
`
`transmission line shared between multiple terminals. There is no such need for such
`
`a switchable power supply in lntecom.
`
`lntecom teaches a typical system where
`
`there is no need to switch the power on the bus from 12V to 48V.
`
`Instead, a
`
`constant power supply voltage is typically supplied to ail of the equipment connected
`
`to the bus. Thus, there is no motivation or suggestion in any of these reference to
`
`combine them, absent the use of a hind-sight approach employing the '250 patent
`
`specification as a blueprint to piece together the teachings of the prior art.
`
`Therefore, for one or more of the above reasons, the patentability of claim 1
`
`should be confirmed.
`
`Claims Depending on Independent Claim 1
`
`The claims depending on Claim 1 should be allowable for at least the reason
`
`that claim 1 is allowable and they incorporate the limitations of claim 1.
`
`in addition,
`
`the patent owner offers the following additional arguments about the dependent
`
`claims.
`
`Serial No. 90/009,513
`
`Page :30 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-11
`IPR2016-00574 USPN 8,902,760
`
`
`
`Ciaim2
`
`In his rejection, the Examiner states:
`
`Regarding claim 2, lntecom teaches a current flow in wires carrying high
`
`frequency data (e.g., lntecom at Fig. 1; p. 37, lines 10-18 ("In an overall LAN, many
`
`pieces of equipment, each with its own third and fourth transformers 270, 280, can
`
`take power as well as data from the bus.")), and as set forth above IBM TDB teaches
`
`communicating information about the remote piece of equipment by altering the
`
`current flow. Therefore, for reasons stated above, it also would have been obvious
`
`for the information communicated to the central module to be carried over the same
`
`wires in the cable that normally carry high frequency data communications over the
`
`network to a piece of electronic equipment.
`
`The Patent Owner's Contentions
`
`Claim 2 is set forth below:
`
`2.
`
`The system of claim 1 wherein the information communicated to the
`
`central moduie is over the same wires in the cable that normally carry high frequency
`
`data communications over the network to a piece of electronic equipment.
`
`IBM TDB does not disclose a network much less data communications on a
`
`network. Even if lntecom does disclose data communications on a network it does
`
`not disclose employing separate cabling for each piece of equipment/object much
`
`less disclose the use of separate cabling for each piece of equipment/object to relate
`
`information about a piece of equipment/object to an altered current.
`
`Claim 5
`
`In his rejection, the Examiner states:
`
`Serial No. 90/009,513
`
`Page 31of99
`
`Chrimar Systems, Inc.
`Exhibit 2081-12
`IPR2016-00574 USPN 8,902,760
`
`
`
`Regarding claim 5, the remote module taught by IBM TDB is a device
`
`attached to a piece of equipment at S1, S2, or 832. Therefore, for reasons stated
`
`above, such a claim also would have been obvious.
`
`The Patent Owner's Contentions
`
`Claim 5 is set forth below:
`
`5.
`
`The system of claim 1 wherein a remote module is a device attached to
`
`a piece of equipment
`
`Even
`
`if
`
`the
`
`remote module
`
`is a device attached
`
`to
`
`the piece of
`
`equipment/object IBM TDB does not teach how to relate Information about a piece of
`
`equipment to an altered current because there is no separate cabling for each piece
`
`of equipment/object that connects to the network.
`
`Claim 13
`
`tn his rejection, the Examiner states:
`
`Regarding claim 13, lntecom further teaches the network being an Ethernet
`
`network (e.g., lntecom at p. 26, lines 3-11). Therefore, for reasons stated above,
`
`such a claim also would have been obvious.
`
`The Patent Owner's Contentions
`
`Gia im 13 is set forth below:
`
`13.
`
`The system of claim 1 wherein the network is an Ethernet network.
`
`There is no network in IBM TDB much less an Ethernet network. Even if
`
`there is an Ethernet network in IBM TDB (there is not) or in lntecom, neither employs
`
`separate cabling to relate information about a piece of equipment/object to an altered
`
`current
`
`Seriai No. 90/009,513
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`Page 32 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-13
`IPR2016-00574 USPN 8,902,760
`
`
`
`Claim 15
`
`In his rejection, the Examiner states:
`
`Regarding claim 15, !ntecom further teaches the cables being twisted pair
`
`cables and the network being an Ethernet network (e.g., lntecom at p. 26, lines 3-11;
`
`p. 37, lines 19-28). Therefore, for reasons stated above, such a claim also would
`
`have been obvious.
`
`The Patent Owner's Contentions
`
`Claim 15 is set forth below:
`
`15.
`
`The system of claim 1 wherein the cables are twisted pair Ethernet
`
`cables.
`
`There are no twisted pair Ethernet cables in IBM TDB. Even if there are
`
`twisted pair Ethernet cables in IBM TDB (there is not) or in lntecom, neither employs
`
`separate twisted pair Ethernet cabling to relate information about a piece of
`
`equipment/object to an altered current
`
`Claim 20
`
`In his rejection, the Examiner states:
`
`Regarding claim 20, the current flow taught by lntecom (e.g., lntecom at p. 37,
`
`lines 26-28) and IBM TDB is a DC currently flow, and the altered current flow taught
`
`by !BM TDB includes at least one change in the magnitude of the DC current flow
`
`(IBM TDB teaches changing the magnitude of the current flow by an amount delta
`
`lo). Therefore, for reasons stated above, such a claim also would have been
`
`obvious.
`
`Serial No .. 90/009,513
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`Page 33of99
`
`Chrimar Systems, Inc.
`Exhibit 2081-14
`IPR2016-00574 USPN 8,902,760
`
`
`
`The Patent Owner's Contentions
`
`Claim 20 is set forth below:
`
`20.
`
`The system of claim 1 wherein the current flow is a DC current flow and
`
`the altered current flow includes at least one change in the magnitude of the DC
`
`current flow.
`
`The cited art does not teach how to relate information about a piece of
`
`equipment/object to an altered current regardless of whether the current is DC
`
`current and the altered current includes at least one change in the magnitude
`
`because there is no separate cabling for each piece of equipment/object and,
`
`therefore, there is no teaching as to how to relate information about a piece of
`
`equipment to an altered current much less an altered current wherein the current is
`
`DC current and the altered current includes at least one change in the magnitude.
`
`Claim 21
`
`In his rejection, the Examiner states:
`
`Regarding claim 21, lntecom further teaches a remote module including a
`
`transmitter and the central module including a receiver (e.g., fntecom at p. 37, lines
`
`19-26). Additionally, IBM TDB as applied above teaches this feature in that the
`
`change in current delta Io is transmitted to the central module power source as a
`
`request for switching the supply voltage. Therefore, for reasons stated above, such
`
`a claim also would have been obvious.
`
`The Patent Owner's Contentions
`
`Claim 21 is set forth below:
`
`21.
`
`The system of daim 1 wherein a remote module includes a transmitter
`
`and the central module includes a receiver.
`
`Serial No. 90/009,513
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`Page 34 of 99
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`Chrimar Systems, Inc.
`Exhibit 2081-15
`IPR2016-00574 USPN 8,902,760
`
`
`
`Assuming, arguendo, that lntecom teaches a remote module including a
`
`transmitter and a central module including a receiver, it is submitted that the
`
`combination of references still does not teach how to relate information about a piece
`
`of equipment to an altered current because there is no separate cabling for each
`
`piece of equipmentlobject that connects to a network in the cited art.
`
`Claim 22
`
`In his rejection, the Examiner states:
`
`Regarding claim 22, lntecom further teaches the current flowing through a
`
`center-tap of at least one isolation transformer (e.g., lntecom at Fig. 2; p. 37, lines 2-
`
`9 ("Positive and negative inputs 261, 262 of the equipment 260 are coupled to the
`
`center taps 274, 284 of the windings 270, 280 of the third and fourth transformers
`
`270, 280, respectively, to allow the power supply 210 to transmit the power. ... "); p.
`
`38; lines 1-8 ('The first, second, third and fourth transformers 220, 230, 270, 280
`
`therefore act as isolation transformers, isolating the DC bias of the power subsystem
`
`from data inputs on the equipment 260."). Therefore, for reasons stated above, such
`
`a claim also would have been obvious.
`
`The Patent Owner's Contentions
`
`Claim 22 is set forth below:
`
`22.
`
`The system of claim 1 wherein the current flows through a center-tap of
`
`at least one isolation transformer.
`
`Assuming, arguendo, that the cited art discloses at least one center-tap
`
`isolation transformer and even if there is current flow to at least one center-tap
`
`transformer, the cited art does not teach how to relate information about a prece of
`
`Serial No. 90/009,513
`
`Page 35 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-16
`IPR2016-00574 USPN 8,902,760
`
`
`
`equipment to an altered current because there is no separate cabling for each piece
`
`of equipment/object that connects to a network in the cited art.
`
`Claim 23
`
`In his rejection, the Examiner states:
`
`Regarding claim 23, the remote module of lntecom is integrated into the !STE
`
`equipment (lntecom at Fig. 2 (illustrating the power separation and data filtering
`
`circuits as being located between the two sets of ISTE connectors)). Therefore, for
`
`reasons stated above, such a claim also would have been obvious.
`
`The Patent Owner's Contentions
`
`Claim 23 is set forth below:
`
`23.
`
`The system of claim 1 wherein a remote module is integrated into a
`
`piece of equipment
`
`Assuming, arguendo, that the cited art discloses a remote module integrated
`
`into a piece of equipment, the art does not teach how to relate information about a
`
`piece of equipment to an altered current because there is no separate cabling for
`
`each piece of equipment/object that connects to a network in the cited art.
`
`Claim 24
`
`in his rejection, the Examiner states:
`
`Regarding claim 24, the remote modules taught by lntecom and IBM TDB
`
`each consist of multiple electrical components (e.g., transformers, conductors,
`
`capacitors. switches, comparators, etc.). Therefore, for reasons stated above, such
`
`a claim also would have been obvious.
`
`Serial No. 90/009,513
`
`Page 36 of99
`
`Chrimar Systems, Inc.
`Exhibit 2081-17
`IPR2016-00574 USPN 8,902,760
`
`
`
`The Patent Owner's Contentions
`
`Claim 24 is set forth below:
`
`24.
`
`The system of claim 23 wherein a remote module consists of one or
`
`more electrical components.
`
`Assuming, arguendo, that the cited art discloses that a remote module is for
`
`example one or more electrical components, the cited art does not teach how to
`
`relate information about a piece of equipment to an altered current because there is
`
`no separate cabling for each piece of equipment/object that connects to a network in
`
`the cited art.
`
`Claim 25
`
`ln his rejection, the Examiner states:
`
`Regarding claim 25, the central module (comprising the phantom powering
`
`subsystem) of lntecom is integrated into centralized network equipment i!iustrated in
`
`Figure 1 . Therefore. for reasons stated above, such a claim also would have been
`
`obvious.
`
`The Patent Owner's Contentions
`
`Claim 25 is set forth below:
`
`25.
`
`The system of claim 1 wherein the central module is integrated into
`
`centralized network equipment.
`
`It is submitted that there is no central module that accommodates separate
`
`cabling for each piece of equipment/object in lntecom. Therefore, lntecom does not
`
`disclose a central module being integrated into centralized network equipment.
`
`Serial No. 90/009,513
`
`Page 37 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-18
`IPR2016-00574 USPN 8,902,760
`
`
`
`Claims 26 and 27
`
`In his rejection, the Examiner states:
`
`Regarding claims 26 and 27, lntecom further teaches the centralized network
`
`equipment including several hubs and a patch panel and that the phantom powering
`
`subsystem is integrated into the network backbone on a data-bearing LAN bus
`
`comprising first and second conductors (e.g., lntecom at p. 19, lines 13-17; p. 20,
`
`lines 11-16; p. 21, lines 17-24). Although lntecom is silent as to any specific
`
`connection point of the phantom powering subsystem to the bus conductors, lntecom
`
`does appear to illustrate the connection being prior to the patch panel in Figure 2.
`
`However, one of ordinary skill in the art would recognize that the connection point,
`
`whether integrated into a hub or into the patch panel taught by lntecom, would not
`
`functionally alter the disclosed phantom powering subsystem (i.e., the data inputs on
`
`the network devices would still be isolated from the DC bias, and the DC power
`
`would still be available to the connected equipment), nor would any particular
`
`advantage be gained by an specific integration point Therefore, the integration of
`
`the central module of lntecom into a hub or patch panel would have been obvious to
`
`one of ordinary skill in the art at the time the invention was made as a matter of
`
`routine design choice not affecting the operation of the Jntecom phantom powering
`
`subsystem or otherwise resulting in some unobvious improvement. See !n re
`
`Larson, 340 F.2d 965, 968 (CCPA 1965).
`
`The Patent Owner's Contentions
`
`Claims 26 and 27 are set forth below:
`
`26.
`
`The system of claim 25 wherein the centralized network equipment is a
`
`hub.
`
`Serial No. 90/009,513
`
`Page 38 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-19
`IPR2016-00574 USPN 8,902,760
`
`
`
`27.
`
`The system of claim 25 wherein the centralized network equipment is a
`
`patch panel.
`
`The patent owner contends that Jntecom does not disclose or teach a central
`
`module
`
`that accommodates separate cabling
`
`for each piece of equipment
`
`Therefore, lntecom can not disclose or suggest a central module being integrated
`
`into centralized network equipment even if the centralized network equipment is a
`
`hub or patch panel.
`
`Claim 28
`
`In his rejection, the Examiner states:
`
`Regarding claim 28, both lntecom (e.g., lntecom at Fig. 2 (third pair power
`
`source 410; see also lntecom at p. 28, lines 14-18 (suggesting alternative sources of
`
`power); p. 39, lines 3-8 (suggesting other voltage levels)) and IBM TDB (describing
`
`switching from 12V to 48V) teach the central module including a second power
`
`source. Therefore, for reasons stated above, such a claim also would have been
`
`obvious.
`
`The Patent Owner's Contentions
`
`Claim 28 is set forth below:
`
`28.
`
`The system of claim 1 wherein the central module includes a second
`
`power source.
`
`The cited art does not disclose or suggest a central module
`
`that
`
`accommodates separate cabling for each piece of equipment. Therefore, the cited
`
`art does not disclose or suggest a central module including a second power source.
`
`Serial No. 90/009,513
`
`Page 39 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-20
`IPR2016-00574 USPN 8,902,760
`
`
`
`Claims 29-30
`
`in his rejection, the Examiner states:
`
`Regarding claims 29 and 30,
`
`IBM TDB as applied above teaches the
`
`information being utilized to selectively provide one or more electrical signals to one
`
`or more pieces of equipment, at least one electrical signal being a DC current signal
`
`(the change in current delta lo resulting from the power-on request signal causes the
`
`increase in supply voltage from i2V to 48V for the requesting load). Therefore, for
`
`reasons stated above, such claims also would have been obvious.
`
`The Patent Owner's Contentions
`
`Claims 29 and 30 are set forth below:
`
`29.
`
`(Original) The system of claim 1 wherein the information is utilized to
`
`selectively provide one or more electrical signals to one or more pieces of
`
`equipment.
`
`30.
`
`(Original) The system of claim 29 wherein at least one electrical signal
`
`is a DC current signal.
`
`Absent some specific teaching not found in lntecom or IBM TDB there is no
`
`suggestion
`
`to "selectively" provide any signal
`
`to one or more pieces of
`
`equipment/object because
`
`the
`
`lntecom bus and
`
`the
`
`IBM TDB multiplexed
`
`transmission !ine share an electrical signal with multiple pieces of equipment. This is
`
`regardless of whether the electrical signal is a DC current.
`
`Claim 31
`
`In his rejection, the Examiner states:
`
`Regarding claim 31, the combination of lntecom and IBM TDB as applied
`
`above teaches the wires within which the current flow is altered being the same
`
`Serial No. 90/009,513
`
`Page40 of 99
`
`Chrimar Systems, Inc.
`Exhibit 2081-21
`IPR2016-00574 USPN 8,902,760
`
`
`
`wires used for normal network communication (i.e., IBM TDB teaches altering the
`
`current flow in the transmission wires, and lntecom teaches the transmission wires
`
`being data-bearing LAN conductors (e.g., lntecom at p. 19, lines 13-17; p. 20, lines
`
`11-16)). Therefore, for reasons stated above, such a claim also would have been
`
`obvious.
`
`The Patent Owner's Contentions
`
`Claim 31 is set forth below:
`
`31.
`
`The system of claim 1 wherein the wires within which the current flow is
`
`altered are the same wires used for normal network communication.
`
`IBM TDB does not disclose a network much less data communications on a
`
`network. Even if lntecom does disclose data communications on a network it does
`
`not disclose employing separate cabling for each piece of equipment/object to relate
`
`information about a piece of equipment/object to an altered current.
`
`Claim 32
`
`In his rejection, the Examiner states:
`
`Regarding claim 32, the combination of lntecom and IBM TDB as applied
`
`above teaches the wires within which the current flow is altered being four wires (i.e.,
`
`IBM TDB teaches altering the current flow in the transmission wires, and lntecom
`
`teaches the transmission wires being two twisted pairs of data-bearing LAN
`
`conductors (e.g., fntecom at p. 21, lines 22-29)). Therefore, for reasons stated
`
`above, such a claim also would have been obvious.
`
`The Patent Owner's Contentions
`
`Claim 32 is set forth below:
`
`Serial No. 90/009,513
`
`Page 41of99
`
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