`Petitioner - Apple, Inc.
`Patent Owner - Papst Licensing GmbH & Co., KG.
`IPR2016-01841
`EXH. 2005
`
`1
`
`
`
`Applicant: Michael Tasler
`Application No.: l l/467,092
`Filed: August 24, 2006
`Date: July 17, 2007
`Page — l l —
`
`decision in the KSR case does not overrule and is not inconsistent with the above-noted Gore or
`
`‘Tee Air decisions of the Federal Circuit.
`
`All of the currently pending claims require an automatic and without user imerverztion
`
`feature that allows a computer to understand how to talk to and receive data from the claimed
`
`device without a user having to, for example, load applications software onto a computer before
`
`being able to transfer data to it.
`
`It is respectfully submitted that, in accordance with the above-
`
`referenced case law, all currently pending claims should be found to be patentable. One reason
`
`for this is that the present invention deviates away from the accepted state of the art evidenced by
`
`the camera, software and scanner references of record, which affirmatively require user
`
`intervention — a user must, for example, load applications software onto a computer to be able to
`
`transfer pictures to it from a digital camera.
`
`The currently pending claims should be found to be patentable for a number of additional
`
`reasons. For example, the new claims further specify that the claimed device is capable of
`
`generating digitized analog data sets before the claimed device is connected to a personal
`
`computer. The undersigned attorney is not aware of any proper combination of references that
`
`teaches or suggests this claim element.
`
`As one example, and assuming for the sake of argument that a “plug and play keyboar ”
`
`is prior art and that it is proper to combine such assumed prior art with a camera reference such
`
`as US Patent No. 5,470,335, such a purported combination of references would not render
`
`obvious the subj ect matter of the currently pending claims. One reason for this is that all claims
`
`require the capability of generating digitized analog data before the claimed device is connected
`
`to a personal computer.
`
`In direct contrast to this, keyboards create useful data only after they are
`
`2
`
`
`
`Applicant: Michael Tasler
`Application No.: ll/467,092
`Filed: August 24, 2006
`Date: July 17, 2007
`Page — 12 —
`
`connected to a personal computer and, therefore, the combination of the keyboard with the ‘335
`
`patent would be able to create useful data on a plug and play basis only after the combination is
`
`connected to a personal computer. For this additional reason, for example, it is respectfully
`
`submitted that all currently pending claims should be found to be patentable.
`
`The Examiner‘s attention is drawn to the fact that each independent claim includes a
`
`dependent claim that recites a combination of a personal computer with the device claimed in the
`
`corresponding independent claim.
`
`It is the specific intention of the client and the undersigned
`
`attorney to ensure that all currently pending claims are first directly infringed by the manufacture
`
`or sale of the claimed device, not by the combination of the claimed device and a personal
`
`computer.
`
`As a follow—up to the previously filed notice of litigation, additional lawsuits involving
`
`Fujifilm, Samsung, Olympus, MEI and JVC have been filed with respect to the same patents at
`
`issue in the previous notice. A multi-district litigation may be declared in the future.
`
`The undersigned attorney requests the Examiner to review all the prior art submitted in
`
`connection with this and the parent application, and to base his decision on the patentability of
`
`the currently pending claims only on the remarks made in this paper, not on arguments or
`
`amendments made in any other paper or any application of which this application claims priority.
`
`It is the specific intention of the applicant that the independent claims noted above should
`
`be interpreted to stand on their own.
`
`In this regard, the limitations of the claims depending from
`
`any dependent claim should not be read into any independent claim for any reason.
`
`3
`
`
`
`Applicant: Michael Tasler
`Application No.: 11/467,092
`Filed: August 24, 2006
`Date: July 17, 2007
`Page —— 13 —
`
`It is respectfully submitted that the new claims are in condition for allowance and,
`
`therefore, a formal notice to that effect is earnestly solicited.
`
`In this regard, the Examiner is
`
`respectfully requested to contact the undersigned attorney upon entry of this amendment.
`
`R spe fu ysubmitte
`
`almon
`.
`y
`ef
`Attorney for Applicant
`Registration No. 37,435
`
`July 17, 2007
`Welsh & Katz, Ltd.
`120 South Riverside Plaza, 22nd Floor
`Chicago, IL 60606
`Telephone (312) 655-1500
`Facsimile (312) 655-1501
`
`4
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
