/7/D
`a.-2v- 0v
`
`IN THE UMTED STATES PATENT AI\D TRADEMARK OF'F'ICE
`
`Art Unit 2665
`Examiner Phuongchau Ba Nguyen
`
`Deepak Mansharamani et al.
`P4506
`09/800,678
`March 6,2001
`System for Fabric Packet Control
`
`In Re:
`Case:
`Serial No.:
`Filed:
`Subject:
`
`To:
`
`The Commissioner of Patents
`PO Box 1450
`Arlington, V A 2231 3-1 450
`
`Dear Sir:
`
`Response D
`
`RECEIVED
`FEB 2 0 2004
`
`TechnologY 0enter 2600
`
`All of the claims standing for examination are presented below. Claims 1, 5 and 9
`
`are herein amended in the present response.
`
`1. (c
`amended) A method for managing data traffic at switching element
`nodes in a fabrilnqtwork, each switching element node having a plurality of input
`
`and output ports,
`
`iqg the steps of:
`
`port, a number of virtual output queues equal
`(a) establishing at each
`to the number of output ports, each vi
`
`utput queue at each individual input
`
`port dedicated to an individual output port,
`
`only packets destined forthe
`
`associated output port, for managing incoming data
`
`(b) accepting or discarding data at each virtual
`
`directed to a
`
`4,1
`
`vt
`
`r-]
`
`Juniper Exhibit 1009
`
`
`a.-2v- 0v
`
`IN THE UMTED STATES PATENT AI\D TRADEMARK OF'F'ICE
`
`Art Unit 2665
`Examiner Phuongchau Ba Nguyen
`
`Deepak Mansharamani et al.
`P4506
`09/800,678
`March 6,2001
`System for Fabric Packet Control
`
`In Re:
`Case:
`Serial No.:
`Filed:
`Subject:
`
`To:
`
`The Commissioner of Patents
`PO Box 1450
`Arlington, V A 2231 3-1 450
`
`Dear Sir:
`
`Response D
`
`RECEIVED
`FEB 2 0 2004
`
`TechnologY 0enter 2600
`
`All of the claims standing for examination are presented below. Claims 1, 5 and 9
`
`are herein amended in the present response.
`
`1. (c
`amended) A method for managing data traffic at switching element
`nodes in a fabrilnqtwork, each switching element node having a plurality of input
`
`and output ports,
`
`iqg the steps of:
`
`port, a number of virtual output queues equal
`(a) establishing at each
`to the number of output ports, each vi
`
`utput queue at each individual input
`
`port dedicated to an individual output port,
`
`only packets destined forthe
`
`associated output port, for managing incoming data
`
`(b) accepting or discarding data at each virtual
`
`directed to a
`
`4,1
`
`vt
`
`r-]
`
`Juniper Exhibit 1009
`
`
`
`predetermined
`
`quantity of q
`
`data reaches or exceeds the thresholdTl
`'/\
`r
`-
`
`when the
`
`2. (original) The
`
`of claim 1 wherein, in step (b), all data is discarded for a
`
`full queue.
`
`6 6 6
`
`a
`at)9Y
`* t | -/'
`{
`
`ri 3. (Cancelled)
`
`I
`
`r 4. (Previously
`manager increases the rate
`
`above the preset threshold,
`
`method of claim 1 wherein in step (b), the queue
`iscarding:s quantity of queued data increases
`data traffic when the queue is full.
`
`5; (Cunently amended) A switch
`
`element node for a fabric network.
`
`comprising:
`
`a plurality of input and
`
`a number of virtual output
`
`at each input port equal to the number
`
`of output ports, each virtual output
`
`at each individual input port dedicated
`
`to an individual output port, storing only
`
`destined for the associated
`
`and
`
`€
`
`E 6
`
`output port , for managing incoming data
`charactenzed in that the a queue
`
`accepts or discards data directed
`
`in the queue relative tffi*t
`to fuw^re according tF. quantity of
`capacity bv monitoffiantity of queued datA against a preset threshold, and
`discarding data froffivirtual output queue u\u nr.artrrmined rate-tegcfu
`when the qu{ntity of queued data reaches or
`
`
`
`,n"r*lh,ur;
`
`,,YL;
`
`.6'i (Origi
`
`t) The switching element of claim'5 wherein all data is discarded for a
`
`full queue.
`
`_/
`7. (Cancelled)
`
`8. (Previously
`
`,l above the preset
`
`\-
`./
`A)Tn\chin4pment of claim 5 wherein the queue
`rate of disch*iqg\d the quantity of queued data increases
`'\.
`ld.
`
`\
`t-? z
`X(Cunently amended)
`
`routers, compflsmg:
`
`data router having external connectirns to other data
`
`an internal fabric
`
`: and
`
`a plurality of swi
`
`element nodes iryfhe internal fabric network, each
`
`switching element node having plurality gfinput and output ports, and at each
`
`input port, a number of virtual
`each virtual output queue at each i
`
`qlEues equal to the number of output ports,
`
`idual input port dedicated to an individual
`
`output port, storing only paclgz$
`
`for the associated output port, for
`
`managing incoming data7ft afftc;
`
`charactefize{rn that the a queue
`rfr quantity
`to fto*uelccording
`capacitylY monitoring the lffiot
`begituto discard data
`
`2
`reaches or exceeds the threshold^ zi
`
`data against a preset threshold, and
`
`at a predetermined rate,
`
`when the quantity of queued data
`
`PI
`
`(-V
`
`E a €a
`
`p5'**--/
`'Ee/,
`,/
`
`€
`
`
`-4-
`
`tz,pflOnginat;
`
`_)
`data router of claimlwherein all data is discarded for a full
`
`queue.
`
`l l (Cancelled)
`
`route: of claim 9 wherein the queue manager
`./
`
`ity of queued data increases above the
`
`
`
`-5-
`
`REMARKS
`
`The present response is filed with a Request for Continued Examination
`
`(RCE), and is to the Office Action mailed in the above-referenced case on
`November 19, 2003,made Final. Claims l, 2, 4-6, 8-10 and 12 arepresented
`
`below for examination. The Examiner has objected to claims 5 and 9 due to
`informalities, and has rejected claims 1,2,4-6,8-10 and 12 under 35 U.S.C.
`
`103(a) as being unpatentable over Khacherian (5,768,257), hereinafter
`
`Khacherian, in view of Aimoto (6,122,252), hereinafter Aimoto.
`
`Applicant has again carefully studied the prior art references cited and
`
`applied by the Examiner, and the Examiner's rejections and statements of the
`
`instant Office Action. In response, applicant herein amends claims 5 and 9 to
`correct the objectionable language, thereby overcoming the ll2 rejection, and
`slightly amends the language of the independent claims to more particularly point
`
`out and distinctly claim the patentable subject matter of applicant's invention, and
`to distinguish applicant's claims unarguably over the prior art. Applicant herein
`
`provides further argument in support of said claim amendments.
`Applicant herein amends the language of claim I to specifically recite that
`
`the queue manager discards data from the virtual output queue at a predetermined
`
`rate when the quantity of queued data reaches the threshold, regardless of the data
`
`source rate to the virtual output queue. For convenience, applicant reproduces
`claim I as amended below.
`
`,,_,
`
`
`
`-6-
`
`Claim I as amended now recites:
`
`1. (Currently amended) A methodfor managing data traffic at switching element
`
`nodes in afabric network, each switching element node having a plurality of input
`
`and output ports, comprising the steps of:
`
`(a) establishing at each input port, a number of virtual output queues
`
`equal to the number of output ports, each virtual output queue at each individual
`
`input port dedicated to an individual output port, storing only packets destinedfor
`the associated output port, for managing incoming data trffic; and
`(b) accepting or discarding data at each virtual output queue directed to a
`
`queue according to the quantity of data in the queue relative to queue capacity by
`
`providing a queue managerfor monitoring quantity of queued data in relation to
`
`a preset threshold, and discarding datafrom the virtual output queue at a
`
`predetermined rate, regardless of the data source rate to the queue, when the
`
`quantity of queued data reaches or exceeds the threshold,
`
`Applicant's independent claims 5 and 9 recite the switching element node
`
`and data router, respectively, for practicing the invention according to the method
`
`of claim 1, and applicant accordingly herein amends the language of those claims
`similarlyto claim l.
`Applicant has previously argued that l(hacherian and Aimoto do not
`explicitly disclose ageug m?qlgg&1m9$!g1ng grantity of q.19ued data in
`relajion to a presg!_thresho-ld, and disc_ardillg ggta { p predetermined rate when the
`quantity of queue data reaches the threshold, and further, that the rute at which
`
`cells are received into the queue of Aimoto is not constant, and is therefore not
`predetermined.
`\
`
`r-{..,.
`
`
`
`-7-
`
`The Examiner has responded in the instant Office Action, stating that
`
`when receiving data from the source(s), the transmit rate of the source makes
`buffer overloading or full at threshold level, thus the buffer will discard exceeded
`cells at the predetermined rate of the transmit source. The Examiner has further
`
`that, firstly, there is not found in the specification nor claim language that the
`"predetermined rate" is the " constant rate", and applicant's argument pertaining to
`that is therefore inelevant, and secondly,thatthe source rate of is the
`predetermined rate, and the cells will be discarded at the predetermined source
`
`rate.
`
`Applicant respectfully traverses the Examiner's position, and must reiterate
`
`that the data source rate is not a rate that has been determined previously, which
`
`would make it a predetermined rate, the data source rate is the variable,
`
`uncontrollable and undetermined rate at which cells arrive at the virtual output
`
`queue, and has no bearing whatsoever on the rate atwhich cells are discarded
`from the virtual output queue of applicant's invention once the cell threshold of
`the virtual output queue is met or exceeded. Applicant's invention is capable of
`discarding cells at rates which are determined based on the cell volume in relation
`
`to the threshold of the virtual output queue, and once the threshold is met or
`
`exceeded, the discard rate may be accelerated as the virtual output queue
`continues to fill above the first threshold.
`Applicant has judicially amended the base claims to specifically recite the
`disassociation between the discard rate and data source rate. Applicant therefore
`believes that independent claims l, 5 and 9 as amended now distinguish clearly
`and unarguably over the prior art references provided by the Examiner, either
`
`singly or combined, as both references fail to teach or suggest discarding dala at a
`predetermined rate regardless of the data source rate to the virtual output queue.
`
`
`
`-8-
`
`Depending claims 2,4,6,8, 10 and 12 arc then patentable on their own merits, or
`
`at least as depended from a patentable claim.
`
`It is therefore respectfully requested that this application be reconsidered, the
`claims be allowed after Final, and that this case be passed quickly to issue. If there
`
`are any time extensions needed beyond any extension specifically requested with
`
`this amendment, such extension of time is hereby requested. If there are any fees
`
`due beyond any fees paid with this amendment, authorization is given to deduct
`
`such fees from deposit account 50-0534.
`
`Respectfully submitted
`
`Deepak Mansharamani et al,
`
`Donald R. Boys
`Reg. No. 35,074
`
`Donald R. Boys
`Central Coast Patent Agency
`P.O. Box 187
`Aromas, CA 95004
`(83r)726-r4s7
`
`!,
`
`
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