`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`LG Electronics, Inc.
`Petitioner,
`
`v.
`FastVDO LLC
`Patent Owner.
`
`
`Patent No. 5,850,482
`________________________
`
`Inter Parte Review No. ____________
`
`___________________________________________________________
`
`January 26, 1998 Amendment in prosecution history of ’482 patent
`
`Exhibit 1010
`
`
`
`,
`don History Date )
`T a
`
`' -o
`D ste :,i-rmation retrieved from USPTO Patent
`Applcation Information Retrieval (PAIR)
`system records at www.uspto.gov
`
`j4'
`
`'I*
`
`At
`
`e
`
`ocket No. 8190-43
`
`PA
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re: Meany and Martens
`Serial No.: 08/633,896
`Filed: April 17, 1996
`ERROR RESILIENT METHOD
`For:
`AND APPARATUS FOR
`ENTROPY CODING
`
`Group Art Unit: 261
`.6
`Examiner: B. Tadayo
`n
`
`January 23, 1998
`
`Assista. Commissioner for Patents
`Washington, DC 20231
`
`c,.
`
`AMENDMENT
`
`Sir:
`
`In response to the Official Action dated July
`24, 1997, please amend the above-identified application
`as follows:
`
`IN THE SPECIFICATION:
`Page 1, line 8, >etween "methods" and
`"apparatus", please insert --and--.
`Page 29, line 35,.pease delete "5A", and
`insert --5B-- therefore.
`Page 30, line 6, pleagedelete "5A", and insert
`--5B-- therefore.
`
`IN THE CLAIMS:
`Please amend independent Claim 1, 7, 12, 22 and
`28 as follows:
`1. (Amended)
`An error resilient method of
`encoding data comprising the steps of:
`generating a plurality of code words
`representative of respective portions of the data,
`wherein each code word comprises a first portion and an
`associated second portion, and wherein said code word
`generating step comprises the steps of:
`
`LA b
`
`Apple Inc. Exhibit 1010 Page 1
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 2
`
`generating the first portion of each
`code word, [the first portion] wherein said first portion
`generating step comprises the step of including
`information within the first portion that is
`representative of a predetermined characteristic of the
`associated second portion; and
`generating the second portion of each
`code word, [the second portion] wherein said second
`portion generating step comprises the step of including
`information within the second portion that is
`representative of the respective portion of the data; and
`providing error protection to at least one of
`the first portions of the plurality of code words while
`maintaining any error protection provided to the
`respective second portion associated with the at least
`one first portion at a lower level than the error
`rotection provided to the respective first portion..
`
`7. (Amended) A data encoding apparatus
`comprising:
`code word generating means for generating a
`plurality of code words representative of respective
`portions of the data, wherein each code word comprises a
`first portion and an associated second portion, and
`wherein said code word generating means comprises:
`first generating means for generating
`the first portion of each code word, [the first portion]
`said first generating means comprising means for
`including information within the first portion that is
`representative of a predetermined characteristic of the
`associated second portion; and
`second generating means for
`generating the second portion of each code word, [the
`second portion] said second generating means comprisin
`means for including information within the second portion
`
`Apple Inc. Exhibit 1010 Page 2
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 3
`
`that is representative of the respective portion of the
`data; and
`
`error protection means for providing error
`protection to at least one of the first portions of the
`plurality of code words while maintaining any error
`protection provided to the respective second portion
`associated with the at least one first portion at a lower
`level than the error protection provided to the
`respective first portion.
`
`4
`
`12. (Amended)
`An error resilient method of
`compressing data comprising the steps of:
`transforming the data based upon a
`predetermined transformation function;
`
`quantizing the transformed data such that the
`quantized data has fewer unique coefficients than the
`transformed data; and
`encoding the quantized data, said encoding step
`comprising the steps of:
`generating a plurality of code words,
`representative of respective portions of the data, which
`have respective first and second portions, wherein [the
`first portion includes] said code word generating step
`comprises the steps of including information within the
`first portion that is representative of a predetermined
`characteristic of the.associated second portion, and
`[wherein the second portion includes] including
`information within the second portion that is
`representative of a respective portion of the data; and
`providing error protection to at
`least one of the first portions of the plurality of code
`words while maintaining any error protection provided to
`the respective second portion associated with the at
`least one first portion at a lower level than the error
`protection provided to the respective first portion.
`
`<z I
`
`Apple Inc. Exhibit 1010 Page 3
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 4
`
`22. (Amended) An error resilient data
`compression apparatus comprising:
`a data transformer for transforming the data
`based upon a predetermined transformation function;
`a data quantizer for quantizing the transformed
`data such that the quantized data has fewer unique
`coefficients than the transformed data; and
`a data encoder for encoding the quantized.data,
`said data encoder comprising:
`code word generating means for
`generating a plurality of code words, representative of
`respective portions of the data, which have -respective
`first and second portions, wherein said code word
`generating means comprises means for including [the first
`portion includes] information within the first portion
`that is representative of a predetermined characteristic
`of the associated second portion, and means for including
`[wherein the second portion includes] information within
`the second portion that is representative of a respective
`portion of the data; and
`error protection means for providin'g
`error protection to at least one of the first portions of
`the plurality of code words while maintaining any error
`protection provided to the respective second portion
`associated with the at least one first portion at a lower
`level than the error protection provided to the
`respective first portion.
`
`28. (Amended) A computer readable memory for
`storing error resilient encoded data, the computer
`readable memory comprising:
`a storage medium for storing the error
`resilient encoded data, said storage medium being
`partitioned into a first error protected data block and a
`second data block, wherein any-error protection provided
`
`Apple Inc. Exhibit 1010 Page 4
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April :7, 1996
`Page 5
`
`by said second data block is at a lower level than the
`error protection provided by said first data block; and
`a plurality of code words, representative of
`respective portions of the original data, which have
`respective first and second portions, wherein the first
`portion of each code word includes information
`representative of a predetermined characteristic of the"
`associated second portion, and wherein the associated
`second portion of each code word includes information
`representative of a respective portion of the original
`data,
`
`wherein at least one of the first'portions of
`the plurality of code words is stored in the first data
`block of said storage medium such that the at least one.
`first portion is error protected, and wherein the
`respective second portion associated with the at least
`one first portion is stored in the second data block of
`said storage medium such that any error protection
`provided to the respective second portion associated with
`the at least one first portion is at a lower level than
`the error protection provided to the respective first
`portion.
`
`REMARKS
`Applicants would like to thank the Examiner for
`the thorough review of the present application and for
`the indication that Claims 4, 15 and 30 define patentable
`subject matter and would be allowable if rewritten in
`independent form. Each independent claim, namely, Claims
`1, 7, 12, 22 and 28, has been amended to more clearly
`define the invention, as explained more fully below. The
`specification has also been amended to correct several
`obvious informalities that were noted during our review
`of the specification in the course of preparing the
`present Amendment. As discussed in detail below, the
`
`Apple Inc. Exhibit 1010 Page 5
`
`
`
`In.re.: Meany and Martens
`Serial No. 08/633,896
`Filed: April 7.7, 1996
`Page 6
`
`amended set of claims includes recitations which further
`patentably distinguish the claimed invention over the
`cited reference.
`
`The Invention
`The claimed invention provides an error
`resilient method and apparatus for entropy coding data
`which includes code word generating means for generating
`a plurality of code words representative of respective
`items in the data set. Each code word has two portions
`which we shall hereafter refer to as "fields", namely, a
`first or prefix field which is susceptible to bit errors,
`and an associated second or suffix field which is
`resilient to bit errors. According to the claimed
`invention, the code words are generated such that a bit
`error in the prefix field of a code word could result in
`a potential loss of code word synchronization,.while a
`bit error in the suffix field of a code word shall only.
`affect that particular code word. More specifically, the
`code words are generated such that a bit error in the
`suffix field of a code word will not result in a loss of.
`code word synchronization, but the resulting misdecoded.
`value shall, instead, fall within a predetermined range
`about the correct value. Thus, according to the claimed
`invention, the error resilient method and apparatus for
`entropy coding data shall be suitable for use with
`unequal error protection such that the prefix fields are
`encoded with a higher level of error protection and the
`suffix fields are encoded with a lower level of error
`protection, if any at all.
`As claimed, the code word generating means
`includes prefix generating means and suffix generating
`means for generating the p efix and suffix fields of each
`n particular, the prefix field
`code word, respectively
`includes information r pre entative of a predetermined
`
`Apple Inc. Exhibit 1010 Page 6
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 7, 1996
`Page 7
`
`characteristic of the associated suffix field. As
`defined by dependent Claims 3, 9, 14, 24 and 29, each
`prefix field preferably includes information
`representative of the predetermined number of characters,
`such as bits, which form the associated suffix field of
`the code word. The prefix field may also include
`information representative of other characteristics of
`the associated suffix field, such as the contiguous or
`consecutive range of coefficient values which the
`associated suffix field may represent. In addition, each
`suffix field includes information representative of
`respective portions of the original data. Consequently,
`even though the suffix fields are not error protected or
`are only provided with a relatively low level of error
`protection, the method and apparatus of the claimed
`invention can correctly determine the length of the
`suffix field of a code word even if there should be of
`one or more bit errors within the said suffix field,
`provided that the associated prefix field is decoded
`correctly, i.e., without the occurrence of a bit error.
`Accordingly, in order to provide a high probability that
`the prefix field is decoded correctly, the method and
`apparatus of the claimed invention encodes the prefix
`field with a higher relative level of error protection.
`According to one advantageous embodiment set
`forth in Claims 12-27 in which the data has been
`quantized, the quantized coefficients can be
`characterized using a "histogram" which is a discrete
`distribution consisting of a number of individual "bins",
`each of which represent the frequency or probability of
`occurrence of a quantized coefficient value. In other
`words, each bin is associated with a particular
`quantization interval which has as its frequency a count
`of the number of occurrences of coefficients whose values
`fall within the associated quantization interval.
`
`Apple Inc. Exhibit 1010 Page 7
`
`
`
`K
`
`In.re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 8
`
`According to this,embodiment of the error
`resilient method and apparatus for encoding data of the
`claimed invention, the prefix field of each code word
`includes information representative of the number of bits
`K which form the associated suffix field of the code
`word. Furthermore, the prefix field can also include
`information representative of the specific histogram bin
`within which quantized coefficient value resides. The
`suffix field will, in turn, identify one particular
`quantized coefficient value within the respective
`histogram bin. In aggregate, the prefix and suffix field
`
`of each code word shall together include information
`representative of a specific coefficient valve residing
`within a specific bin of the quantized coefficient
`histogram.
`
`In other words, the prefix field of this
`exemplary embodiment includes the information
`representative of a set of quantized coefficient values
`while the suffix field includes the information
`representative of a specific coefficient value among the
`set designated by the prefix field. Thus, if the prefix,
`field of a code word is decoded correctly, i.e., without
`the occurrence of a bit error, the length of the
`associated suffix field and the range of coefficient
`values which may be represented by the associated suffix
`field will be known. As a result, the effects of one or
`more bit errors on the suffix field will be isolated to a
`specific code word, thereby limiting such errors to a
`misdecoded coefficient value which is constrained to that
`range of values determined by the prefix field, i.e., the
`range of valves within the respective histogram bin.
`Accordingly, the error resilient method and apparatus for
`encoding data according to the claimed invention
`effectively reduces, if not prevents, catastrophic errors
`in an efficient manner.
`
`Apple Inc. Exhibit 1010 Page 8
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 9
`
`The Amended Claims Are Patentable
`Claims 1-3, 5-14 and 16-29 were rejected under
`35 U.S.C. §103 as being unpatentable over U.S. Patent No.
`5,289,501 to Seshadri et al. Each of the independent
`claims, namely, Claims 1, 7, 12, 22 and 28, have been
`amended to further patentably distinguish the claimed
`invention over the cited reference, as explained in
`detail below.
`The Seshadri '501 patent describes a technique
`for transmitting information in digital form over fading
`channels. In order to provide error protection for the
`transmitted information, the technique described by the
`Seshadri '501 patent accepts a stream of data that has
`been subdivided into different classes that merit
`different levels of error protection. For example, the
`class of data meriting the highest level of error
`protection may be the most important data.and/or the data
`most susceptible to error, while the class of data
`meriting the lowest level of error protection may be the
`least important data and/or the data least susceptible to
`errors. Once the different classes have been separately.
`scrambled, each class is redundancy coded using a
`differeht, respective channel code. Thus, the technique
`described by the Seshadri '501 patent provides unequal
`error protection to the different classes of data.
`Following encoding of the data, the encoded data is
`modulated prior to being transmitted over free space
`communication channels to remote digital cellular mobile
`radio cell sites.
`Like the Seshadri '501 patent, the data
`encoding method and apparatus of the claimed invention
`utilizes unequal error protection to provide different
`levels of error protection. With respect to the claimed
`invention, for example, the first portions of the code
`words have a higher level of error protection than the
`
`Apple Inc. Exhibit 1010 Page 9
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 10
`
`second portions of the code words since the first
`portions of the code words contain information of more
`relative importance than the information contained by the
`second portions of the code words. In this regard,
`conventional unequal error protection techniques, such as
`described by the Seshadri '501 patent, are discussed in
`the background of the invention section of the present
`application at page 10, lines 19-33.
`However, the Seshadri '501 patent does not
`teach or suggest the unique manner in which the first and
`second portions of the code words (also referred to as
`the prefix and suffix portions of the code words,
`respectively) are generated as now set forth more clearly
`by each independent claim. Since each of the independent
`claims includes similar recitations, independent Claim 1
`will be hereinafter discussed in detail for purposes of
`illustration. As a result, Applicants submit that. each
`of the other independent claims are also patentable for.
`each of the reasons set forth below in conjunction with
`Claim 1.
`
`As set forth by amended independent Claim 1,
`the error resilient method of encoding data generates a
`plurality of code word representing the data. Each code
`word includes a first portion and an associated second
`portion. According to the claimed invention, the step of
`generating the plurality of code words includes the step
`of generating the first portion of each code word which,
`in turn, has now been defined to further include "the
`step of including information within the first portion
`that is representative of a predetermined characteristic
`of the associated second portion". Likewise, the step of
`generating the plurality of code words also includes a
`step of generating the second portion of each code word
`which, in turn, has now been further defined to include
`"the step of including information within the second
`
`Apple Inc. Exhibit 1010 Page 10
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 11
`
`portion that is representative of the respective portion
`of the data". Only after generating the first and second
`portiohs of the code words, however, does the error
`resilient method of encoding data of independent Claim 1
`provide unequal error protection to the first and second
`portions of the code words such that the first portions
`are error protected at a higher level than the associated
`second portions.
`As described above, one common example of the
`error resilient method of encoding data set forth by
`amended independent Claim 1 includes the generation of
`code words in which the first portion defines the length
`of the associated second portion while the second portion
`actually identifies a particular coefficient value,
`typically a quantized coefficient value. In instances in
`which the coefficient values are arranged in a histogram
`having a number of superbins, the first portions of the
`code words can also identify the respective superbin in
`which the associated second portions reside. See, for
`example, Figure 5B for an illustration of a histogram and
`the information provided by the first and second portions
`of the code words.
`In this example, since a bit error in the first
`portions could result in the potential loss of code word
`synchronization while a bit error in the second portions
`would only affect one individual code word, the first
`portions of the code words are of significantly more
`importance and are therefore error protected at a higher
`level than the associated second portions. In fact, even
`if a bit error occurs in the second portion of a code
`word, the first portion of the code word will still
`generally be able to identify the superbin within which
`the coefficient 'value resides such that the actual range
`of values within which the coefficient value would fall
`can be determined.
`
`Apple Inc. Exhibit 1010 Page 11
`
`
`
`In re: Meany and Martens
`Serial No. 08/633,896
`Filed: April 17, 1996
`Page 12
`
`In contrast to the claimed invention, the
`Seshadri '501 patent does not teach or suggest the step
`set forth by independent Claim 1 of generating a
`plurality of code words, each of which includes a first
`portion and an associated second portion. More notably,
`the Seshadri '501 patent does not teach or suggest the
`step of "generating the first portion of each code word,
`wherein said first portion generating step comprises a
`step of including information within the first portion
`that is representative of a predetermined characteristic
`of the associated second portion", as now recited by
`amended independent Claim 1. Further, the Seshadri '501
`patent does not teach or suggest the step of "generating
`the second portion of each code word, wherein said second
`portion generating step comprises a step of including
`informationwithin the second portion that is
`representative of the respective portion of the data'!", as
`now also recited by amended independent Claim 1.
`Thus, even though the data encoding method and
`apparatus of the claimed invention and the Seshadri '501
`patent each utilize unequal error protection, the data
`encoding method and apparatus of the claimed invention
`includes a number of other aspects which are not taught
`or suggested by the Seshadri '501 patent and which
`significantly contribute to the efficiency with which the
`data encoding method and apparatus encodes data so as-to
`effectively reduce, if not prevent, catastrophic errors
`in an efficient manner.
`Although amended independent Claim 1 has been
`described in detail above and a number of recitations set
`forth by amended independent Claim 1 have been
`highlighted that are not taught or suggested by the
`Seshadri '501 patent, each of the other independent
`claims, namely, independent Claim 7, 12, 22 and 28,
`include similar recitations. As such, the claimed
`
`Apple Inc. Exhibit 1010 Page 12
`
`
`
`In re: Meany and Marten
`Serial No. 08/633,896
`Filed: April k7, 1996
`Page 13
`
`., 4,/
`
`invention set forth by these other amended independent
`claims are also not taught or suggested by the Seshadri
`'501.patent for each of the reasons set forth above in
`conjunction with amended independent Claim 1.
`Accordingly, Applicants submit that amended independent
`Claims 1, 7, 12, 22 and 28, as well as the claims which
`depend therefrom, are not taught or suggested by the
`Seshadri '501 patent.. Therefore, the rejections of the
`claims, as amended, are overcome.
`
`CONCLUSIQN
`In view of the amended specification, the
`amended claim and the remarks presented above, it is
`respectfully submitted that all of the claims of the
`present application are now in condition for allowance.
`It is therefore respectfully requested that a Notice of
`Allowance be issued in due course. The Examiner is
`encouraged to contact Applicants' undersigned attorney to
`resolve any remaining issues in order to expedite
`examination of the present application.
`
`Respeclly
`
`subm' ted,
`
`Regis rion No. 34,610
`
`BELL SELTZER INTELLECTUAL PROPERTY LAW GR P
`ALISTON & BIRD LLP
`Post Office Drawer 34009
`Charlotte, NC 28234
`Tel (704) 331-6000
`Fax (704) 334-2014
`
`CERTIFICATE OF MAILING
`
`I hereby certify that this correspondence is being deposited with the
`United States Postal Service as first class mail in an envelope
`addressed to:
`Assistant Commissioner for Patents, Washington,
`DC 20231, on January 23, 1998.
`
`E1 abeth Herbener
`
`306825
`
`Apple Inc. Exhibit 1010 Page 13
`
`
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