receive from the data capture device, over the established short-range
`
`paired wireless connection, information of one or more new media files
`
`that can be transferred from the data capture device to the mobile device;
`
`and
`
`receive an input through a graphical user interface (QUI) corresponding to
`
`selecting one or more of the new media files, using the information of one
`
`or more new media files received from the data capture device;
`
`send to the data capture device, over the established short-range paired
`
`wireless connection, information of the selected one or more new media
`
`files for transfer to the mobile device; and
`
`receive the selected one or more new media files from the data capture
`
`device, over the established short-range paired wireless connection,
`
`wherein the mobile device is configured to receive an input through the
`
`graphical user interface (QUI) to select the received new media file for
`
`transfer to a remote website.
`
`receive a message from the data capture device, over the established short
`
`range paired wireless connection, wherein the message corresponds to
`
`theinformation of one or more new media files for transfer from the data
`
`capture device to the mobile device;
`
`receive an input through a graphical user interface (GUI) corresponding to
`
`selecting one or more of the nevl media files using the information of one
`
`or more media files;
`
`send a message to the data capture de>tice, over the established short range
`
`paired wireless connection, wherein the message corresponds to
`
`12
`
`Canon Exhibit 1002, Page 99
`
`

`

`information of one or more nevl media files selected for transfer from the
`
`data capture device to the mobile device;
`
`receive encrypted data from the data capture device, over the established
`
`short range paired wireless connection, wherein the received encrypted
`
`data corresponds to the one or more media files selected for transfer to the
`
`mobile device, wherein the mobile device is configured to obtain the one
`
`or more new media files selected for transfer to the mobile device from the
`
`received encrypted data using the cryptographic encryption key; and
`
`receive an input through the graphical user interface (GUI) to select an
`
`obtained media file for transfer to a remote web service.
`
`Claim 22 (currently amended): The system of claim 21, wherein the mobile device is
`
`configured to send a hypertext transfer protocol (HTTP) request to the remote website
`
`wherein the HTTP request comprises user publishing information, and wherein the user
`
`publishing information comprises user information, website information, and the received
`
`new media file. wherein the mobile device is preconfigured to attach a user identifier, an
`
`action setting and a destination web address of a remote web service to the obtained new
`
`media file, wherein the user identifier uniquely identifies a particular user of the remote
`
`web service, wherein action setting comprises one of a remote procedure call (RPC)
`
`method and hypertext transfer protocol (HTTP) method.
`
`Claim 23 (currently amended): The system of claim 22, wherein the user information
`
`corresponds to identity of the user on the remote website. identifier comprises one or
`
`more of user name, user password, user device information, and user information.
`
`Claim 24 (currently amended): The system of claim 21, wherein the software mobile
`
`application on the mobile device is preconfigured configured to send a message to the
`
`data capture device, over the established short-range paired wireless connection, wherein
`
`the message comprises a user preference for configuring the data capture device prior to
`
`13
`
`Canon Exhibit 1002, Page 100
`
`

`

`acquiring the new media, and wherein the user preference comprises one of delete new
`
`media, new media type to acquire and a timer, new media size to acquire, new media
`
`format to acquire and a new media compression technique to use.
`
`Claim 25 (currently amended): The system of claim 21, wherein the internet access
`
`capability of the mobile device is via a cellular data network wireless technologies
`
`comprising one of 2G, 3G, 4G, 5G, LAN, 'NAN, and 'Ni Fi.
`
`Claim 26 (original): The system of claim 21, wherein the information of one or more new
`
`media files comprises one or more of name, size, media type and format of the one or
`
`more new media files.
`
`Claim 27 (currently amended): A short-range wireless enabled data capture device
`
`compnsmg:
`
`a short range communication module with pairing capability;
`
`a non-volatile memory device module;
`
`a processor;
`
`a module for generating a cryptographic encryption key;
`
`[[said]]J! short-range wireless communication module configured to control the
`
`processor to establish for establishing a short-range paired wireless connection
`
`between the short-range wireless enabled data capture device and a short-range
`
`wireless enabled with an internet connected mobile device, wherein the short(cid:173)
`
`range paired wireless connection is one of ~Bluetooth paired connection,~ Wi-Fi
`
`paired connection protocol method that uses pairing, and other personal area
`
`wireless networking technologies that use pairing uses pairing, and wherein the
`
`14
`
`Canon Exhibit 1002, Page 101
`
`

`

`short range is short range radio frequency that is most effective for data transfer
`
`when de>tices are less than 100 meters apart;
`
`said module for receiving, over the established short range paired wireless
`
`connection, a message from the mobile device, wherein the received message
`
`comprises a user preference corresponding to one of delete new media, new
`
`media type to acquire, new media size to acquire, new media format to acquire
`
`and a new media compression technique to use;
`
`said module for processing the received user preference instructions, wherein
`
`processing comprised configuring the data capture device based on the user
`
`preference;
`
`a data capture module configured to control the processor to acquire new media
`
`and create a new media file in the short-range wireless enabled data capture
`
`device said module for acquiring new media after configuring the data capture
`
`de>tice based on the user preference, wherein new media is acquired and a new
`
`media file is created after establishing the short-range paired wireless connection
`
`between the data capture device and the mobile device, wherein the new media
`
`file is stored in the memory module, and wherein the new media file comprises
`
`one or more of new audio data, new video data, new image data, new text data,
`
`new digital data and data associated with the acquired new media;
`
`said non-volatile memory device for storing new media file;
`
`~[[said]] module configured to control the processor to receive for receiving, over
`
`the established short range paired wireless connection, a message from the mobile
`
`device, over the established short-range paired wireless connection, wherein the
`
`received message comprises a user preference corresponding to one of delete new
`
`media, new media type to acquire, and timer asking for information of one or
`
`more new media files that can be transferred from the data capture device to the
`
`15
`
`Canon Exhibit 1002, Page 102
`
`

`

`mobile device, wherein the information of one or more new media files comprises
`
`one or more of name, size, media type and format of the one or more new media
`
`fils&·
`'
`
`said module configured to control the processor to process the received user
`
`preference, wherein processing comprises the processor performing action based
`
`on the received user preference;
`
`said module configured to control the processor to process a data transfer request
`
`initiated by the mobile device, wherein processing comprises:
`
`said module controlling the processor to receive a message from the
`
`mobile device, over the established short-range paired wireless
`
`connection, wherein the message corresponds to asking for information of
`
`one or more new media files that can be transferred from the data capture
`
`device to the mobile device;
`
`said module controlling the processor to send to the mobile device, over
`
`the established short-range paired wireless connection, information of one
`
`or more new media files that can be transferred from the data capture
`
`device to the mobile device; and
`
`said module controlling the processor to receive from the mobile device,
`
`over the established short-range paired wireless connection, information of
`
`one or more new media files selected for transfer to the mobile device;
`
`said module configured to control the processor to transfer the selected one or
`
`more new media files to the mobile device, over the established short-range
`
`paired wireless connection, wherein the mobile device is configured to receive the
`
`transferred one or more new media files, wherein the mobile device is configured
`
`to transfer the received new media file to a remote website by sending a hypertext
`
`16
`
`Canon Exhibit 1002, Page 103
`
`

`

`transfer protocol (HTTP) request over a cellular data network, wherein the HTTP
`
`request comprises user publishing information, and wherein the user publishing
`
`information comprises user information, website information, and the received
`
`new media file.
`
`said module for sending, over the established short range paired wireless
`
`connection, a reply message to the mobile device containing the information of
`
`one or more new media files for transfer from the data capture device to the
`
`mobile device;
`
`said module for receiving, over the established short range paired wireless
`
`connection, a message from the mobile device containing information of one or
`
`more new media files selected for transfer from the data capture device to the
`
`mobile device;
`
`said module for processing the received information of selected one or more new
`
`media files; and
`
`said short range communication module for transferring data of the one or more
`
`new media files selected for transfer to the mobile device, over the established
`
`short range paired wireless connection, wherein transferring the data comprises
`
`encrypting the data using the generated cryptographic encryption key, wherein the
`
`mobile device is configured to receive the encrypted data and obtain the one or
`
`more new media files selected for transfer to the mobile device, using the
`
`cryptographic encryption key, and wherein the mobile device is configured to
`
`transfer an obtained new media file to a remote web service.
`
`Claim 28 (canceled).
`
`Claim 29 (currently amended): The short-range wireless enabled data capture device of
`
`claim 27, wherein the user information corresponds to identity of the user on the remote
`
`17
`
`Canon Exhibit 1002, Page 104
`
`

`

`website identifier comprises one or more of user name, user passvlord, user device
`
`information, and user information.
`
`Claim 30 (canceled).
`
`Claim 31 (new): The short-range wireless enabled data capture device of claim 27,
`
`wherein the information of one or more new media files comprises one or more of name,
`
`size, media type and format of the one or more new media files.
`
`18
`
`Canon Exhibit 1002, Page 105
`
`

`

`Remarks
`
`The Present invention and the Pending Claims
`
`This invention, in general, relates to distribution of multimedia content. More
`
`particularly, this invention relates to pairing a digital data capture device in conjunction
`
`with a mobile device for automatically publishing data and multimedia content on one or
`
`more websites simultaneously.
`
`Claims 1, 3-5,7-10, 12, 13, 19,21-27,29 and 31 are currently pending. Reconsideration
`
`and allowance of the pending claims is respectfully requested.
`
`Summary of the Office Action
`
`Claim Rejections -35 USC § 103
`
`Claims 1, 8-9 are rejected under 35 U.S.C. 103(a) as being unpatentable over Kennedy
`
`US 20030157960 in view of Anttila US 20050139680.
`
`Claims 2-4 are rejected under 35 Pre-AlA U.S.C. 103(a) as being unpatentable over
`
`Kennedy US 20030157960 in view of Anttila US 20050139680further in view of Pryor
`us 20050273592.
`
`Claims 5-7 are rejected under 35 Pre-AlA U.S.C. 103(a) as being unpatentable over
`
`Kennedy-Anttila further in view of Ihara US 20120089538.
`
`Claims 10-30 are rejected for similar reason as stated above.
`
`Amendments to the Claims
`
`Claims 1, 3-5, 7, 9-10, 12, 13, 19,21-24,27, and 29 are currently amended.
`
`Claims 2, 6, 11, 14-18, 20, 28 and 30 are canceled.
`
`19
`
`Canon Exhibit 1002, Page 106
`
`

`

`Claim 31 is new.
`
`The office action further states: "Claims 1, 8-9 are rejected under 35 U.S.C. 103(a) as being
`
`unpatentable over Kennedy US 20030157960 in view of Anttila US 20050139680."
`
`In response, applicant submits that Kennedy in view of Anttila does not teach or
`
`suggest all the limitations in applicant's amended claim 1.
`
`First argument: Establishing a "paired" wireless connection between the data
`
`capture device and the mobile device before acquiring "new media"
`
`Applicant discloses a method and system for media transfer from a Bluetooth
`
`(BT) enabled digital data capture device to a Bluetooth (BT) enabled mobile device.
`
`First, a short-range "paired" wireless connection is established between the BT
`
`enabled data capture device and the BT enabled mobile device. "New media" is
`
`acquired by the Bluetooth enabled data capture device after the short-range paired
`
`wireless connection is established (see page 6, lines 5-29, and page 7 lines 1-2 of
`
`applicant's original application).
`
`Office action states that paragraphs [0021] and [0032-0034] of Kennedy teach
`
`establishing a paired wireless connection between the data capture device and the mobile
`
`device before acquiring new media. Applicant respectfully disagrees with the above
`
`statement for the following reasons.
`
`Kennedy in view of Anttila does NOT teach or disclose a step of establishing a
`
`short-range paired wireless connection between the data capture device and the mobile
`
`device before acquiring new media.
`
`Kennedy does not disclose "establishing pairing" between two devices. The
`
`word "pairing" is NOT disclosed in Kennedy. Paragraph [0021] of Kennedy cited in the
`
`office action discloses: "In the event that device 75 does not have enough capacity to
`
`20
`
`Canon Exhibit 1002, Page 107
`
`

`

`store the data, the user can then transmit it to remote storage 25 via an intermediate
`
`electronic device 50." In Kennedy, the images are acquired first and stored in the
`
`memory of the digital capture device. When there is a memory crunch in the digital
`
`capture device, the digital capture device sends the images to the remote storage device
`
`using the mobile device as an intermediate electronic device that provides connection to
`
`the remote storage device. Therefore, in case of Kennedy, a pairing is not established first
`
`between the digital capture device and the mobile device before the digital capture device
`
`starts acquiring "new media".
`
`For the reasons stated above, applicant submits that Kennedy in view of Anttila
`
`does not teach or suggest the following limitation in claim 1:
`
`"establishing a short-range paired wireless connection between the data capture
`
`device and the mobile device".
`
`Second Argument: Time of acquiring "New media"
`
`Applicant discloses that the "new media" is acquired by the image capture
`
`device after a short-range paired wireless connection has been established with the
`
`mobile device.
`
`Kennedy does not disclose acquiring "new media" after establishing a short-range
`
`paired wireless connection. In contrast, Kennedy discloses, inter alia, that the data is
`
`acquired by the camera before the non-paired connection is established with the mobile
`
`device. In Kennedy, when the accumulated data size of all the captured pictures taken
`
`by the camera reaches a memory threshold set by the user, the camera connects with
`
`the mobile device, sends the data that has already been acquired in the memory, and then
`
`disconnects the connection to the mobile device (see Kennedy paragraph [0032] cited in
`
`the office action).
`
`From the above paragraph, it is clear that Kennedy follows the following
`
`sequence to transfer data:
`
`21
`
`Canon Exhibit 1002, Page 108
`
`

`

`(a) camera detects the memory to be full or nearly full,
`
`(b) initiates a connection to the cell phone, and
`
`(c) transfers data and then disconnects (see Kennedy paragraph [0032]);
`
`Further, Kennedy discloses that a camera may be configured for any one of a
`
`plurality of operational modes such as real-time upload, automatic upload or manual
`
`upload (see Kennedy paragraph [0010]).
`
`In real-time mode, the camera disclosed by Kennedy transfers its data to a home(cid:173)
`
`based server as soon as the data is acquired and as quickly as the wireless connections
`
`allow (see Kennedy FIG. 2, element 100, home-based server, and paragraph [0031]). In
`
`real-time mode, the camera does Not check if a paired connection is pre-established
`
`with the mobile device. For example in Kennedy's case, when the non-paired BT
`
`connection is unavailable, to make sure the pictures are sent "as quickly as the wireless
`
`connections allow", the camera in Kennedy will have to save the pictures in its local
`
`memory until the non-paired connection between the mobile and data capture device is
`
`established and then send the pictures when "the wireless connection allows". Therefore,
`
`in Kennedy, there is no pre-check to ascertain that the paired connection to the
`
`mobile device is available.
`
`For the reasons stated above, applicant submits that Kennedy in view of Anttila
`
`does not teach or suggest the following limitation in claim 1:
`
`"acquiring new media, wherein the new media is acquired and a new media file is
`
`created after establishing the short-range wireless pairing between the data
`
`capture device and the mobile device".
`
`22
`
`Canon Exhibit 1002, Page 109
`
`

`

`Third Argument: Data transfer initiated by the Mobile Device VS data transfer
`
`initiated by the Data Capture device
`
`Applicant discloses that after a paired connection is established between the
`
`mobile device and the data capture device, and after "new media" is acquired by the data
`
`capture device, the mobile device initiates a data transfer process. The mobile device
`
`initiates a data transfer process by sending a message to the data capture device.
`
`The data capture device receives the message from the mobile device, where the message
`
`corresponds to asking the data capture device for information of one or more new media
`
`files that can be transferred from the data capture device to the mobile device (see page 7,
`
`lines 6-9 of applicant's original application -"The client application 203 then initiates the
`
`transfer of the captured data, the multimedia content, and the associated files in a pull
`
`mode of operation.").
`
`Office action states that paragraph [0033] of Kennedy that describes a "manual
`
`mode" of data transfer teaches applicant's above limitation. Applicant respectfully
`
`disagrees with the above statement for the following reasons:
`
`Kennedy paragraph [0010] recites as follows: "Manual mode lets the user decide
`
`when to perform the upload by activating a control on the portable electronic device."
`
`It is therefore clear that the manual mode in Kennedy is initiated by the user from the
`
`BT Enabled Image Capture Device and NOT from the BT Enabled Mobile Device.
`
`23
`
`Canon Exhibit 1002, Page 110
`
`

`

`As you can see in Manual
`Mode [0033]
`
`"The user may then
`arbitrarily decide to transfer
`data using the user interface
`210."
`
`The 21 0 l.Jser !nterfa.ce
`Element is on the Olgita!
`C"amera and NC)-'f on tJ1e
`
`·-rt·1~2'r~:~ ~s N~) §~1"tt~~~s::a~1~~ frt-,f~"'1
`ttlt~ ~1t)ilih~ ti:t~~··ic-{~ to -u·1e
`
`Kennedy Fig. 2
`
`Further, Kennedy paragraph [0033] recites as follows: "In manual mode, the user
`
`decides when to perform the transfer. The memory capacity remaining may be
`
`displayed on display 250. As illustrated in FIG. 2 of Kennedy, reproduced above, the
`
`user may then arbitrarily decide to transfer data using the user interface 210. The camera
`
`would then fulfill the user's request by making a connection to the cell phone, transferring
`
`the data, and then disconnecting." It is clear that in the case of Kennedy, the User
`
`Interface Element 210 is on the Digital Camera and NOT on the Mobile Device. There
`
`is NO message from the Mobile device to the Digital Camera in the Manual Mode, as
`
`claimed by the applicant.
`
`Kennedy also discloses a Hybrid mode of data transfer. However, even in Hybrid
`
`Mode [0034 Kennedy], the initiation of media transfer is performed by the Digital
`
`Camera device and NOT upon receipt of a message from the Mobile Device selecting the
`
`files to be transferred from the digital camera to the mobile device.
`
`24
`
`Canon Exhibit 1002, Page 111
`
`

`

`Kennedy, paragraph [0034] discloses: "In another hybrid mode, the camera 75
`
`may be set in manual data transfer mode, but the camera 75 may also initiate an
`
`automatic transfer if the buffer is getting full in the event that the user hasn't started a
`
`data transfer in time." Therefore, in Kennedy there is NO message from the mobile
`
`device for initiating the data transfer of New Media.
`
`Kennedy further discloses a real-time mode of data transfer. However, even in
`
`real-time mode, the camera transfers its data to a home-based server as soon as the data is
`
`acquired and as quickly as the wireless connections allow (see Kennedy FIG. 2, element
`
`100, home-based server, and paragraph [0031]). Therefore, in Kennedy, even in real-time
`
`mode, initiation of data transfer is NOT performed by the mobile device
`
`Therefore, Kennedy in view of Anttila does not teach or suggest the following
`
`limitation in claim 1:
`
`"processing a data transfer request initiated by a software application on the
`
`mobile device, comprising:
`
`receiving, a message from the mobile device, over the established short(cid:173)
`
`range paired wireless connection, wherein the message corresponds to
`
`asking for information of one or more new media files that can be
`
`transferred from the data capture device to the mobile device;
`
`sending to the mobile device, over the established short-range paired
`
`wireless connection, information of one or more new media files that can
`
`be transferred from the data capture device to the mobile device; and
`
`receiving from the mobile device, over the established short-range paired
`
`wireless connection, information of one or more new media files selected
`
`for transfer to the mobile device".
`
`25
`
`Canon Exhibit 1002, Page 112
`
`

`

`Fourth Argument: Transfer the "received new media file" to remote a website
`
`After receiving information of one or more new media files selected for transfer,
`
`applicant's data capture device transfers the selected one or more new media files to the
`
`mobile device, over the established short-range paired wireless connection. The mobile
`
`device is configured to receive the transferred one or more new media files and transfer
`
`a received new media file to a remote website.
`
`Office action states that paragraphs [0033 -0034] of Kennedy disclose
`
`transferring data of the one or more new media files selected for transfer to the mobile
`
`device, over the established short-range paired wireless connection. The office action
`
`further states that paragraphs [0033 -0034] of Kennedy teach that the mobile device is
`
`configured to transfer the received new media file to a remote website. Applicant
`
`respectfully disagrees with the above statement for the following reasons.
`
`Kennedy and Anttila either alone or in combination do NOT teach or suggest:
`
`"transferring data of the one or more new media files ... ", and
`
`" ... mobile device is configured to transfer the received new media file to a
`
`remote website."
`
`The reason being that neither Kennedy nor Anttila use "Paired" connections to
`
`transfer data and therefore both Kennedy and Anttila do NOT disclose "Pairing" the
`
`mobile device with a data capture device.
`
`•
`
`Furthermore, in applicant's case "new media" file is media acquired
`
`after establishing a pairing between the image capture device and the mobile
`
`device. In case of Kennedy, the images are captured first and when the file size of
`
`images in the memory of the image capture device reaches a threshold value, the
`
`images are transferred to the remote storage device via the mobile device.
`
`26
`
`Canon Exhibit 1002, Page 113
`
`

`

`•
`
`Even in case of Anttila, the file to be transferred from the first device to
`
`the second device pre-exists in the memory of the first device before the
`
`connection is established between the first and the second device. The first device
`
`displays to the second device, using the visual code, the address of the first
`
`device, and the location of the file (see Anttila, FIG.3 Elements 410 and 430, and
`
`paragraph [0028]). Further, after the second device decodes the visual code, the
`
`first device transfers the file to the second device (see Anttila FIG.3 Elements 400
`
`and 480, and paragraph [0028]). Therefore, even Anttila does not disclose
`
`acquiring new media after a connection is established between the two devices.
`
`Therefore, Kennedy in view of Anttila does not teach or suggest the following
`
`limitations in claim 1:
`
`"transferring the selected one or more new media files to the mobile device,
`
`over the established short-range paired wireless connection, wherein the mobile
`
`device is configured to receive the transferred one or more new media files,
`
`wherein the mobile device is configured to transfer the received new media
`
`file to a remote website by sending a hypertext transfer protocol (HTTP) request
`
`over a cellular data network, wherein the HTTP request comprises user publishing
`
`information, and wherein the user publishing information comprises user
`
`information, website information, and the received new media file"
`
`Fifth Argument: Storing acquired new media file in a non-volatile memory device
`
`Applicant's amended claim 1 recites that "new media file" is stored in a "non(cid:173)
`
`volatile memory". The "new media file" is acquired after establishing a short-range
`
`paired wireless connection. Neither Kennedy nor Anttila teach or suggest that a new
`
`media file is acquired after establishing a short-range paired wireless connection and the
`
`acquired new media file is stored in a non-volatile memory of the data capture device.
`
`27
`
`Canon Exhibit 1002, Page 114
`
`

`

`As explained on pages 22-25 of this response, Kennedy teaches several modes for
`
`data transfer. However, none of these modes store media or data in a non-volatile
`
`memory of the camera, where the media or data is acquired after establishing a short(cid:173)
`
`range paired wireless connection with a cell phone. In contrast, in Kennedy, the camera
`
`initiates a connection to the cell phone, transfers media or data and then disconnects
`
`(see Kennedy paragraph [0032]).
`
`Even in the case of Anttila, a new media file is not acquired and stored in a non(cid:173)
`
`volatile memory of a first device after establishing a short-range paired wireless
`
`connection with a second device. In contrast, in Anttila, the first device sends location
`
`information of data to a second device and the second device establishes a
`
`communication link to receive the existing data from the known location of the first
`
`device (see Anttila, Abstract).
`
`Therefore, Kennedy in view of Anttila does not teach or suggest the following
`
`limitation in claim 1:
`
`"storing the new media file in a non-volatile memory".
`
`For the reasons stated above, applicant submits that even if Kennedy and Anttila
`
`are combined as suggested in the office action, there is no reasonable expectation of
`
`success in arriving at applicant's claim 1.
`
`Applicant therefore submits that claim 1 is non-obvious over Kennedy, in view of
`
`Anttila, and respectfully requests that the rejection of claim 1 under pre-AlA 35 U.S.C.
`
`103(a) be reconsidered and withdrawn.
`
`Claims 8 and 9 are dependent on claim 1. Since claim 1, is non-obvious over
`
`Kennedy, in view of Anttila, dependent claims 8 and 9 are also non-obvious over
`
`Kennedy, in view of Anttila. Applicant therefore respectfully requests that the rejection
`
`of claims 8 and 9 under pre-AlA 35 U.S.C. 103(a) be reconsidered and withdrawn.
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`Canon Exhibit 1002, Page 115
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`The office action further states: "Claims 2-4 are rejected under 35 Pre-AlA U.S.C.
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`103(a) as being unpatentable over Kennedy US 20030157960 in view of Anttila US
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`20050139680 further in view of Pryor US 20050273592."
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`Claim 1 is amended to recite the limitation of claim 2 (now canceled) in a
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`modified form. Claim 1 recites that the mobile device is configured to transfer the
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`received new media file to a remote website by sending a hypertext transfer protocol
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`(HTTP) request over a cellular data network. The HTTP request comprises user
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`publishing information, where the user publishing information comprises user
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`information, website information, and the received new media file.
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`Office action states that Anttila, paragraphs [0005, 0014] teaches user identifier
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`and Pryor [0008, 0027 and FIG. 3] teaches HTTP header.
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`Applicant respectfully disagrees with the above statement for the following
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`reasons.
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`First argument: Website User Information VS Bluetooth Identity global ID
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`Applicant discloses that the HTTP request comprises user publishing
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`information, where the user publishing information comprises user information.
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`Applicant's amended claim 3 recites that the user information corresponds to
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`identity of the user on the remote website. Anttila DOES NOT disclose a website user
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`and therefore does NOT teach applicant's claim limitation "wherein the HTTP request
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`comprises user publishing information, and wherein the user publishing information
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`comprises user information" or "wherein the user information corresponds to identity of
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`the user on the remote website".
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`In contrast, Anttila [0005, 0014] teaches, inter alia, "a unique Bluetooth Identity
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`called global ID". This is VERY different from the applicant's user information which
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`29
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`Canon Exhibit 1002, Page 116
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`corresponds to identity of the user on a website like Flickr or eBay or a blog. Anttila's
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`Bluetooth identity "global ID" is used by the Bluetooth Device to indicate the profile of
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`the Device and the capability of the device. Anttila's Bluetooth Global ID is NOT the
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`same as applicant discloses user information for a user "Jane" for a blog website or
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`flickr website.
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`Second argument: Native media VS wirelessly transferred media
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`Applicant discloses that the mobile device is configured to transfer the "received
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`new media file" to a remote website by sending a hypertext transfer protocol (HTTP)
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`request over a cellular data network. The HTTP request comprises user publishing
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`information, where the user publishing information comprises user information, website
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`information, and the "received new media file". In applicant's case, the mobile device
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`receives the new media file from a data capture device.
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`Pryor [0008, 0027] does NOT teach sending a HTTP request comprising user
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`publishing information that in tum comprises user information, website information, and
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`the "received new media file", where the new media file is received from another
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`wirelessly connected device (data capture device). In contrast, Pryor discloses, inter
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`alia, that the HTTP is applied to media data that is NATIVE to the computer. In Pryor
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`the HTTP is NOT applied to media that is "received from a data capture device over a
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`paired short-range wireless connection", or for that matter any wireless link.
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`Difference between Native vs received (non-native) data may be illustrated as
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`follows:
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`Consider an example of a PC connected to a normal home wireless router. In
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`every day scenario, the PC attaches a hypertext transfer protocol (HTTP)_header and user
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`ID to the Data generated by the PC (NATIVE data). The normal home wireless router
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`DOES NOT apply website user information or apply HTTP to the data sent over the
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`wireless from the PC to the home wireless router. In the applicant's case, the mobile
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`device is configured to send a HTTP request comprising the website user information and
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`30
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`Canon Exhibit 1002, Page 117
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`the NON-NATIVE data. In the applicant's case, the mobile device is acting as more than
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`just a normal home wireless router. The wireless pairing established is therefore VERY
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`important for NON-Native data that is acquired by a physically separate device and then
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`transferred to the mobile device over the trusted