Papst Licensing GmbH & Co., KG.
`Petitioner - Apple, Inc.
`Patent Owner - Papst Licensing GmbH & Co., KG.
`IPR2016-01840
`EXH. 2002
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`1
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`

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`Applicant: Michael Tasler
`Application No.: Not yet assigned
`Filed: Herewith
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`Date: August 24, 2006
`Page— 8 -
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`Operating A Scanner Which Emulates A Disk Drive," is not prior art to any of the
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`claims submitted herewith. The earliest US filing date of this patent (March 20,
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`1997) is sixteen days after the earliest effective filing date of the currently
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`pending claims, which is the March 4, 1997 filing date of German application no.
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`197 08 755. The Examiner's confirmation of this is earnestly solicited.
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`US Patent No. 5,508,821 is entitled "Image Scanner And Image Forming
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`Apparatus With An Interface For Connection With An External Computer."
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`Column 4, lines 21—23 of this patent state that the "image scanner 20 emulates the
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`file system of ‘UNIX’ as if it were a hard disc. Accordingly, the image scarmer 20
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`looks like the hard disc from the workstation 21 can be handled as a hard disk."
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`In the summary of the invention of this patent, it is stated that an "object" of the
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`invention is to provide an "image scanner" that "requires no preparation of any
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`new device driver."
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`US Patent No. 5,844,961 is entitled “Filmless Digital X—Ray System.” Figure 4
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`of the patent shows an “electronics package 480” that is a part of a “digital
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`cassette.” Column 10, lines 4-9 of the patent state that the “electronics package
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`480 defines an area that will allow for an electronic system being included in the
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`digital cassette 200. The electronics system will be able to process the
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`information captured by the imaging array system 450 and communicate that
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`information to the computer 220.” Column 11, line 10 through column 13, line
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`12 disclose “digital cassette and the computer communications.”
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`US Patent No. 5,131,089 is entitled "Solid State disk Drive Emulation."
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`2
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`

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`Applicant: Michael Tasler
`Application No.: Not yet assigned
`Filed: Herewith
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`Date: August 24, 2006
`Page - 9 -
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`The abstract of this patent states that the "system permits software written for use
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`with floppy disks to be used with solid state memory devices such as RAM cards
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`or ROM without modification of the software."
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`US Patent No. 4,642,759 is entitled "Bubble Memory Disk Emulation."
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`A two page printout of text included with Windows 95 is submitted
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`herewith concerning the "RAMDRIVESYS" command. This document states
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`that this command allows a computer's RAM memory to simulate a hard disk
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`drive.
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`Figure l of US Patent No. 5,724,574 discloses a hardware arrangement that
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`includes, for example, a high speed scanner 24, a local area network 10, an optical
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`disk based document server 15, and a number of workstations 18.
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`An article entitled "Optical Server Uses Network Protocol For Plug-And-
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`Play lntegration" was published in 1993. Page two of this article states that
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`"emulation of the magnetic file system with a WORM-specific file system in this
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`manner has several distinct advantages. The principal advantage is that the
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`WORM disk appears to applications and utilities as just another disk."
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`The manual for Polaroid's Digital Camera model no. PDC—2000 indicates
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`that it was published in 1996. The Examiner is asked to assume, for the sake of
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`argument, that this is the case. Applicant reserves the right to challenge this in all
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`forums and proceedings other than the examination of this application.
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`Page 11 of the manual states that the "PDC-2000 camera is a Small
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`Computer Systems Interface (SCSI) device," that one can "connect up to seven
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`3
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`

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`Applicant: Michael Tasler
`Application No.: Not yet assigned
`Filed: Herewith
`
`Date: August 24, 2006
`Page —— 10 —
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`SCSI devices to your computer," and that the "PDC-2000 camera's SCSI ID is
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`preset to 4 at the factor."
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`Page 83 of the manual states that to "transfer and work with pictures from
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`the PDC-2000 camera on your PC, you use the PDC-2000 TWAIN driver .
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`.
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`." or
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`one can install "PDC—2000 Direct" software.
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`The currently pending claims clearly are supported by the specification as originally
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`filed. As one example, all of the currently pending claims generally require that a digitized
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`analog data set be representative of electromagnetic radiation that is representative of an object
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`that is physically separated from and located not in substantial proximity to an analog data
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`generating and processing device (ADGPD). These claim features are supported, for example,
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`by the "diagnostic radiology system" disclosed in paragraph 5 of the specification of the instant
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`application.
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`An example of such a "diagnostic radiology system" is, for example, an x-ray machine,
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`the x-rays being one example of the claimed "analog wave signals." As readily apparent to one
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`of ordinary skill in the relevant art, typical x-ray machines include two housings — one in which
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`an x-ray generator is mounted and a second one in which an x-ray transducer is mounted. The x-
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`ray generator is physically separated from and not located in substantial proximity to the
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`transducer so that, for example, a patient can position his or her leg between the generator and
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`the transducer. The transducer creates a set of analog data that comprises an x~ray so that, for
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`example, a user can determine whether the patient‘s leg is broken.
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`It should be noted that the scope of the currently pending claims is not limited to
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`"diagnostic radiology systems" and or to systems that only produce "X-rays." In this regard,
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`4
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`

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`Applicant: Michael Tasler
`Application No.2 Not yet assigned
`Filed: Herewith
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`Date: August 24, 2006
`Page — 11 —
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`other "modes" of practicing the claimed invention include, for example, the CCD device of a still
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`camera that is exposed to ambient light with or without a flash, and that creates therefrom an
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`analog data set that is representative of a picture.
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`For the Examiner's information, the inclusion of the above—described subject matter in the
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`currently pending claims is one reason that the Examiner should find the new claims submitted
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`herewith patentable over, for example, the prior art of record that discloses the use of document
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`scanners (e.g., US Patent Nos. 5,508,821, 5,532,825 and 5,724,574). In contrast to the currently
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`pending claims, the scanner references teach a light source that is located inside the scanner and
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`that is located in substantial proximity to the CCD of the scanner. Such sensors are not adapted
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`to process electromagnetic radiation that is not in substantial proximity to the scanner housing.
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`For this reason alone, the currently pending claims should be found to be patentable over the
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`scanner references.
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`A still further aspect of the currently pending claims that is fully supported by the
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`originally filed specification follows. All of the claims presented in this preliminary amendment
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`generally require that the ADGPD send a response signal that allows a PC to automatically and
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`without user intervention recognize that it can communicate with the ADGPD as if it were a
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`commercially available mass storage device even though it is not a commercially available mass
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`storage device. See, for example, paragraph 54 of the specification submitted herewith, which
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`states that the use of the present invention includes “simulating a virtual mass storage device.”
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`The word “virtual” in this context refers, for example, to the fact that a personal computer is led
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`to believe that it is communicating with a commercially available mass storage device when, in
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`actuality, it is communicating with an analog data generating and processing device. See also,
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`5
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`

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`Applicant: Michael Tasler
`Application No.: Not yet assigned
`Filed: Herewith
`
`Date: August 24, 2006
`Page — I2 —
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`for example, paragraph 23 of the specification, which recites:
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`"The digital signal processor 13 receives this inquiry instruction via the
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`first connecting device and generates a signal which is sent to the host device (not
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`shown) again via the first connecting device 12 and the host line 11. This signal
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`indicates to the host device that, for example, a hard disk drive is attached at the
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`interface to which the INQUIRY instruction was sent."
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`It is respectfully submitted that no prior art reference of record, either taken alone or in a
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`purported combination, teaches or suggests the combinations claimed in the currently pending
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`claims for a number of different reasons. As one example, US Patent No. 5,508,821 does not
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`teach or suggest, for example, the above-noted "automatic recognition" feature because, for
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`example, the system disclosed therein is UNIX based. As readily apparent to one of ordinary
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`skill in the relevant art, such UNIX based systems affirmatively require user intervention in order
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`to operate and use the scanner disclosed in the ’821 patent.
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`As a further example of the patentability of the currently pending claims, the camera
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`disclosed in the Polaroid manual submitted (assuming, for argument's sake, that it is prior art)
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`cannot be automatically recognized without human intervention. In this regard, user intervention
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`always is required because, for example, a user needs to make sure that the camera’s SCSI
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`identification number does not conflict with the ID number of any other device in a daisy chain
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`of which the camera forms a part. For this reason alone, for example, the currently pending
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`claims should be found to be patentable over the Polaroid camera manual (assuming, for
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`arguments sake, that it is prior art).
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`It is respectfully submitted that the new claims are in condition for allowance and,
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`6
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`

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`Applicant: Michael Tasler
`Application No.: Not yet assigned
`Filed: Herewith
`
`Date: August 24, 2006
`Page — l3 —
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`therefore, a formal notice to that effect is earnestly solicited. In this regard, the Examiner is
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`respectfully requested to contact the undersigned attorney upon entry of this amendment.
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`Re2.. f.2Y Submit’
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`Attorney tor Applicant
`Registration No. 37,435
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`August 24, 2006
`Welsh & Katz, Ltd.
`120 South Riverside Plaza, 22nd Floor
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`Chicago, IL 60606
`Telephone (312) 655-1500
`Facsimile (312) 655-1501
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