Therefore, new data and user information are transferred to the website using
`
`HTTP. Support for the amended claims can also be found in the following lines in the
`
`applicant's original application:
`
`Page 3, lines 29-31: "The client application selects the websites for publishing the
`
`transferred data and the multimedia content based on user preferences configured on the
`
`Bluetooth enabled mobile device."
`
`Page 4, lines 2-4: "The client application on the BT enabled mobile device
`
`automatically publishes the transferred data and multimedia content on one or more
`
`websites using the settings configured by the user."
`
`Page 14, lines 11-14: "After the captured image is transferred to the mobile device
`
`202, the client application 203 publishes the capture image on the selected websites
`
`based on the default timer and website settings configured by the user 502 on the mobile
`
`device 202."
`
`Further, page 13, line 30 to page 14, line 1 discloses: "The user 502 may capture
`
`an image using the digital camera. The client application 203 on the mobile device 202
`
`detects the captured image and initiates the transfer of the captured image and the
`
`associated files"; page 14, lines 6-11 of the original application discloses: "The user 502
`
`may set preferences in the mobile device 202. The user preferences, for example,
`
`comprise the websites selected for publishing the transferred image. The user 502 may
`
`select websites, for example, Flickr™, Picasa™, YouTube™, eBay®, etc. and store the
`
`preferences on the mobile device 202. The user 502 may also set the timer setting for
`
`publishing the transferred image on the selected websites"; page 15, lines 3-11 of the
`
`original application discloses: "Consider an investigative reporter, Jane, working for a
`
`prominent newspaper in New York City. Each day, she moves around the city chasing
`
`leads, interviewing people, videotaping her stories, taking pictures, and tracking down
`
`her next big story. When she is working on a story with an associate writer, she may need
`
`to upload her videos and pictures and send it immediately to the associate writer. The
`
`29
`
`Canon Exhibit 1002, Page 200
`
`

`

`method and system disclosed herein enables Jane to automatically upload pictures and
`
`videos taken using her digital camera or video camera onto a mobile device 202 and
`
`publish the pictures, videos, etc. from her mobile device 202 to the internet 501 with one
`
`click or touch of a button"; and page 15, lines 13-15 discloses: "On one click or touch of
`
`a button, the pictures and videos are published and immediately made available on Jane's
`
`private blog that may be accessed by the newspaper editor and her associates in the news
`
`office." Therefore, the website receives the new-media and posts the new-media on the
`
`private blog of the user Jane based on the user information transferred along with the
`
`new-media.
`
`Furthermore, the word "user" is mentioned more than 80 times and the word
`
`"information" is mentioned more than 6 times in the original application.
`
`In view of the above remarks, applicant submits that amended claims 1 and 4 are
`
`fully supported by the original application.
`
`Amended claims 10 and 21 are synonymous with amended claim 1. Applicant
`
`therefore submits that amended claims 10 and 21 are fully supported by the original
`
`application.
`
`Claims 3, 4, 5 and 9 are dependent on claim 1. Claims 12, 13 and 19 are
`
`dependent on claim 10. Claims 22-26 are dependent on claim 21. Applicant therefore
`
`submits that dependent claims 3, 4, 5, 9, 12, 13, 19, and 22-26 are fully supported by the
`
`original application.
`
`Claims 7, 8, 27, 29 and 31 are canceled in this response. Rejection of claims 7, 8,
`
`27, 29 and 31 is therefore moot.
`
`Therefore, applicant respectfully requests that the rejection of claims 1, 3, 4, 5, 9,
`
`10, 12, 13, 19, and 21-26 under 35 U.S.C. 112, first paragraph be reconsidered and
`
`withdrawn.
`
`30
`
`Canon Exhibit 1002, Page 201
`
`

`

`New claim 32 is synonymous with amended claim 1. Applicant therefore submits
`
`that new claim 32 is fully supported by the original application.
`
`New claims 33-36 are dependent on claim 32. New claim 37 is dependent on
`
`claim 10. New claim 38 is dependent on claim 21. Applicant therefore submits that
`
`dependent claims 33-38 are fully supported by the original application.
`
`Specification Objection
`
`The office action further states: "The disclosure is objected to because of the
`
`following informalities: Examiner has reviewed the specification of this application
`
`under examination and could not find support for the additional limitations as
`
`claimed described above. Appropriate correction is required."
`
`In response, applicant submits that the claim amendments and the support table in
`
`pages 21-27 illustrate that the pending claims 1, 3-5, 9, 10, 12, 13, 19,21-26, and 32-38
`
`are fully supported in the specification. Therefore, applicant respectfully requests that the
`
`specification objection be reconsidered and withdrawn.
`
`Claim Rejections -35 USC§ 103
`
`The office action further states: "Claims 1, 3, 8-9 are rejected under 35 Pre-AlA
`
`U.S.C. 103(a) as being unpatentable over Kennedy US 20030157960 Lin US
`
`20050113131 further in view of Hardman US 20040059941."
`
`In response to the above rejection, applicant submits the following arguments:
`
`First argument: "Lack of Pairing" vs "Short-Range Paired Wireless Connection"
`
`31
`
`Canon Exhibit 1002, Page 202
`
`

`

`Applicant establishes a "short-range paired wireless connection" between the
`
`digital camera device and the cellular phone before acquiring "new-media".
`
`Claim 1 discloses a method and system for transferring "new-media" from a
`
`digital camera device to a cellular phone. First, a "short-range paired wireless
`
`connection" is established between the digital camera device and the cellular phone.
`
`"New-media" is acquired by the digital camera device after the short-range paired
`
`wireless connection is established (see page 7, lines 3-7 of the original application).
`
`The office action on page 7 states that paragraph [0010] of Kennedy teaches
`
`establishing a paired BT connection between the data capture device and the cellular
`
`phone before acquiring new-data. Applicant respectfully disagrees with the above
`
`statement for the following reasons.
`
`Kennedy does NOT teach or suggest "establishing pairing" between two devices.
`
`The word "pairing" is not disclosed by Kennedy. Paragraph [0010] of Kennedy cited
`
`in the office action discloses: "the portable electronic device generally transfers its data
`
`as the data is acquired and as quickly as the wireless connections will allow." In real-time
`
`mode, the camera disclosed by Kennedy 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]). In the real-time mode,
`
`the camera does not check if a paired connection is pre-established with the cellular
`
`phone. For example, in the Kennedy reference, when a non-paired BT connection to the
`
`cellular phone 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 cellular phone and the camera
`
`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 BT connection to
`
`the cellular phone is available.
`
`32
`
`Canon Exhibit 1002, Page 203
`
`

`

`Lin also does NOT teach or suggest a step of establishing a "short-range
`
`paired wireless connection" between the earphone and the cellular phone before
`
`acquiring "new temperature measurements". The word "pairing" is not disclosed by
`
`Lin.
`
`Each data flow disclosed in Kennedy and Lin occurs on a non-paired connection.
`
`Furthermore, even Hardman does NOT teach or suggest a step of establishing
`
`a "short-range paired wireless connection" between the digital camera device and the
`
`cellular phone before acquiring "data".
`
`For the reasons presented above, applicant submits that Kennedy in view of Lin
`
`further in view of Hardman does not teach or suggest the following limitations in claim 1:
`
`"establishing a short-range paired wireless connection between the digital camera
`
`device and the cellular phone, wherein the short-range paired wireless connection
`
`is one of a Bluetooth paired wireless connection, a Wi-Fi paired wireless
`
`connection, and other personal area wireless networking technologies that use
`
`pairing;"
`
`"acquiring new-media, wherein the new-media is acquired after establishing the
`
`short-range paired wireless connection between the digital camera device and the
`
`cellular phone;"
`
`Second argument: "Cryptographically authenticating identity of the cellular phone"
`
`v/s "lack of cryptographically authentication identity of the cellular phone".
`
`Amended claim 1 recites that "establishing a short-range paired wireless
`
`connection comprises cryptographically authenticating identity of the cellular
`
`phone".
`
`33
`
`Canon Exhibit 1002, Page 204
`
`

`

`Kennedy does NOT teach "Cryptographically authenticating identity of the
`
`cellular phone"
`
`Lin does NOT teach "Cryptographically authenticating identity of the cellular
`
`phone"
`
`Hardman does NOT teach "Cryptographically authenticating identity of the
`
`cellular phone"
`
`Therefore, Kennedy, in view of Lin further in view of Hardman does not teach or
`
`suggest the above limitation.
`
`Third Argument: "Receiving a data transfer request for the already existing new(cid:173)
`
`media file" v/s "lack of data transfer request for already acquired data"
`
`Page 7 Lines 1-12 of the applicant's original application discloses: "The user
`
`captures 104 data and multimedia content using the digital data capture device 201. The
`
`data and multimedia content may, for example, comprise image files, audio files, video
`
`files, text files, or any combination thereof. The client application 203 on the mobile
`
`device 202 detects 105 the captured data, the multimedia content, and files associated
`
`with the captured data and the multimedia content. The client application 203 then
`
`initiates the transfer of the captured data, the multimedia content, and the associated files.
`
`The office action on page 7 states that paragraph [0020] of Kennedy discloses this
`
`step. Applicant respectfully disagrees for the following reasons.
`
`Paragraph [0020] of Kennedy discloses as follows: "The portable electronic
`
`device permits a user to take data that is acquired and or stored in the device and offload
`
`the data to an external remotely coupled device to make room for more data in the
`
`portable electronic device."
`
`34
`
`Canon Exhibit 1002, Page 205
`
`

`

`Paragraph [0020] of Kennedy indicates that the data capture device offloads the
`
`data to an external remotely coupled device (for example remote storage device) in order
`
`to free the memory of the data capture device for acquiring more data. It does not
`
`disclose (a) the digital camera device acquires new-media only after establishing a short(cid:173)
`
`range paired wireless connection with the cellular phone, (b) the cellular phone detects
`
`the new-media acquired by the digital camera device, and (c) the cellular phone initiates
`
`the data transfer by sending a data transfer request to the digital camera device, over the
`
`established short-range paired wireless connection, where the data transfer request
`
`initiates the transfer of the already existing new-media file.
`
`Figure below shows that applicant's state machine is very different from
`
`Kennedy's state machine.
`
`35
`
`Canon Exhibit 1002, Page 206
`
`

`

`State Machine taught by #Kennedy'~
`and affirmed by PTAB
`Portable Electronic Device {75}1 Data
`Intermediate
`Capture Device
`Electronic Device
`{50}1 Mobile Device
`
`II~ I
`
`. . r ... ~
`
`connect:on to the
`~
`eel! phone, transfers·"".,:
`~
`data and then
`!
`disconnect" {0032]
`'. ....... :--.
`
`Kennedy State
`
`Machine
`
`Mobile
`Device
`
`short-range
`'Nireless
`capability
`
`Rec.eive request to
`transfer the already
`created New Media
`File overthe paired
`connections.
`
`Receive The New
`
`Capture Device and
`Store the New
`Media File
`
`36
`
`Canon Exhibit 1002, Page 207
`
`

`

`Kennedy either in paragraph [0020] or elsewhere in his application does not
`
`disclose the digital camera device performing the following steps:
`
`(a) Establishing a short-range paired wireless connection with the cellular phone,
`
`(b) Acquiring new-data after establishing the short-range paired wireless
`
`connection, and
`
`(c) Receiving a data transfer request from the cellular phone that initiates the
`
`transfer of the already acquired new-media file.
`
`The office action, on page 8 further states that paragraphs [0020], [0023]-[0025]
`
`of Lin disclose this step. Applicant respectfully disagrees for the following reasons.
`
`Paragraph [0020] of Lin discloses: "The local Bluetooth device 150 can
`
`automatically send out a start command SC for the Bluetooth earphone 100 to start with
`
`the process of measuring body temperature."
`
`Paragraph [0023] of Lin discloses: "A Bluetooth earphone activates a temperature
`
`measuring procedure according to the start command inputted by a local Bluetooth device
`
`(step 310)."
`
`Paragraph [0024] of Lin discloses: "Set the mobile phone to send a start command
`
`at a certain time to activate the Bluetooth earphone to execute body temperature
`
`measuring (step 420)."
`
`Paragraph [0025] of Lin discloses: "the mobile phone automatically activates a
`
`pre-set timing for the Bluetooth earphone to measure body temperature (step 520)."
`
`Further, Paragraph [0020] of Lin discloses: "Take the application of the Bluetooth
`
`mobile phone for example, a department director can choose to send a text message of
`
`37
`
`Canon Exhibit 1002, Page 208
`
`

`

`measuring body temperature to the colleagues. After having received the text message,
`
`the mobile phone will issue a start command SC activating the Bluetooth earphone 100 to
`
`measure the body temperature."
`
`Therefore, in Lin, the measurement of temperatures by the earphone is triggered
`
`by the text message received by the mobile phone from an external source (the Director),
`
`which in tum causes the mobile phone to issue a start command to the earphone.
`
`In contrast, in applicant's method, the capture of the new-media by the digital
`
`camera device is NOT triggered by receiving a Text Message on the cellular phone
`
`from an external source. In applicant's method, the cellular phone sends a data transfer
`
`request to the digital camera device that initiates the transfer of the already existing new(cid:173)
`
`media file to the cellular phone over the short-range paired wireless connection.
`
`Figure below shows that the applicant's "new-media and data transfer
`
`request based" state machine is very different from Lin's "text message and start
`
`command based" state machine.
`
`38
`
`Canon Exhibit 1002, Page 209
`
`

`

`Mobile
`Device
`
`~
`""' "" "" ""' "" "" ""' ""' "'' '"' ""*' l
`Establishing a short-range [)<Jineg wireless
`.... c>:<pf<>gr<q.<i>h~tilt' .. ""to{;"'l<!h,:Hi~g ... .... ..:,.,.J
`
`short-range
`t·'lf:reless
`capabi'ity
`
`-----------------------------------------------------------------------
`Timing of Acquiring media
`is. Befnre
`Data Transfer request is received
`
`- te transft!rthe q!r.!':i:!!IY
`Rectuest t(l hl~tl:a
`Med.ia File
`~r..~PJ~_!;fJ'!:~W,..._,...
`'"'"
`'"'"' "''''
`,. ........
`.............
`
`. ._,,,-..
`
`; .................. -..:
`
`Receive request lD
`transfer the aJ'readv
`created New Medi-a
`FUe O\ler the pa~red
`connect~ons.
`
`Tr~nster the~_l~ad
`_ __ J.~£!"~itt~.£tiPV'ewM
`.
`·
`·'-'"'-"
`'''-'
`"-w-
`_
`ed1a I=Jle
`'"'''
`,.._...._,
`x-......_..
`._,....,
`................... ..._ .......
`
`.............
`
`~
`............. ''''·~~
`Receive The N-ew
`~
`.~
`~
`~~ ......... Med~a :FUe coming
`'
`~~,-
`~~,
`-
`.
`_
`-:-r0rr. p~~reu. Dat.:.
`~~ ... -·
`Capture De\• ice and
`~
`Sto·re the New
`
`_..],
`
`I MediaFile
`
`'
`
`~-... ........... ..._,-..
`f"''' ................
`.... ..._..._
`'"''' ~
`~
`li:'ie HTTp
`~
`§S ·:...
`~ -!.~~.lli"V::..,d N' to Tt')nsfer the
`lll>er lnf~rm"'w. Media 1=/le &
`~
`atlon to Webs he
`'
`
`short-range
`\!"-.,.ire~ess
`up2.bilitv
`
`Earphone
`Device
`
`Lin State Machine
`
`Mobile
`Device
`
`short-range
`'tl•.:ke!ess
`
`Ttmin1;; for Acquiring
`data is Aftm·
`receivhg the
`"Start Command"
`
`39
`
`Canon Exhibit 1002, Page 210
`
`

`

`In Lin's disclosure, the Director is the Master that sends a text message to the
`
`mobile phone and the mobile phone in tum sends "Start Command to the earphone to
`
`capture temperatures". In applicant's method, the request is for the data that has already
`
`been captured.
`
`Again, in paragraphs [0020] [0023] [0024] [0025] Lin does not disclose that the
`
`digital camera device performs the following steps:
`
`(a) Establishing a short-range paired wireless connection with the cellular phone,
`
`(b) Acquiring new-media after establishing the short-range paired wireless
`
`connection, and
`
`(c) Receiving a data transfer request from the cellular phone that initiates the
`
`transfer of the already acquired new-media file to the cellular phone.
`
`Hardman also does NOT teach or suggest (a) pairing the digital camera device
`
`and the cellular phone, (b) acquiring new-data by the digital camera device after
`
`establishing the short-range paired wireless connection with the cellular phone, (c)
`
`software application on the cellular phone detecting the new-media acquired by the
`
`digital camera device, and (d) digital camera device receiving a data transfer request from
`
`the software application on the cellular phone that initiates the transfer of the already
`
`existing new-media file to the cellular phone.
`
`Therefore, Kennedy in view of Lin further in view of Hardman does not teach or
`
`suggest the following limitation in claim 1:
`
`"receiving a data transfer request initiated by a software application on the
`
`cellular phone, over the established short-range paired wireless connection,
`
`wherein the data transfer request is for the already existing new-media file;"
`
`40
`
`Canon Exhibit 1002, Page 211
`
`

`

`Fourth Argument: "Data transfer initiated by the Cellular phone" VS "Data
`
`transfer initiated by the Digital camera device"
`
`Applicant discloses that after a paired connection is established between the
`
`cellular phone and the digital camera device, "new-media" is acquired by the digital
`
`camera device. After that, the cellular phone initiates a data transfer process by
`
`sending a data transfer request to the digital camera device. The digital camera
`
`device receives the_data transfer request from the cellular phone that initiates the
`
`transfer of the already existing new-media file to the cellular phone (see page 7, lines
`
`5-7 of applicant's original application: "The client application 203 then initiates the
`
`transfer of the captured data, the multimedia content, and the associated files.").
`
`Kennedy paragraph [0010] discloses 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 in the manual mode in Kennedy, data transfer is
`
`initiated by the user from the Digital camera device and NOT from the Cellular
`
`Phone (see Kennedy FIG. 2 reproduced below).
`
`41
`
`Canon Exhibit 1002, Page 212
`
`

`

`As you can see in Manual
`Mode [0033]
`
`"The user may then
`arbitrarily decide to transfer
`data using the user intetiace
`210."
`
`Kennedy Fig. 2
`
`Further, Kennedy paragraph [0033] discloses 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 cellular phone,
`
`transferring the data, and then disconnecting." It is clear that in Kennedy, the User
`
`Interface Element 210 is on the Digital Camera and NOT on the Cellular Phone. There
`
`is NO data transfer request from the Cellular Phone to the Digital Camera in the Manual
`
`Mode that initiates the data transfer of already existing New-Media.
`
`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 data transfer request from the Cellular Phone.
`
`42
`
`Canon Exhibit 1002, Page 213
`
`

`

`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 data transfer request from the cellular phone
`
`that initiates the transfer of the already existing New-Media file to the cellular phone.
`
`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, there is NO data transfer request from the cellular phone that initiates the transfer
`
`of already existing New-Media.
`
`Lin also does NOT disclose sending data transfer request for already acquired
`
`data. In Lin, the mobile phone receives a text message from an external source (the
`
`Director) and then sends a "Start Command" to the earphone to "measure" the
`
`temperatures. It is "not to transfer temperatures that were already measured"
`
`before receiving the "Start command". The distinction is very important because in the
`
`applicant's method the data transfer request is for the media file that already exists on the
`
`digital camera device.
`
`"Start Command" to capture data is NOT the same as "Data transfer request for
`
`already existing media file".
`
`It is clearly illustrated by the timing of acquiring the data in Lin state machine and
`
`Applicant's state machine.
`
`43
`
`Canon Exhibit 1002, Page 214
`
`

`

`Data Capture
`
`~-~~;~~~nge r·iliwJ·] Device
`
`capab~!~tv
`
`·
`
`Mobile
`Device
`
`5hort-range
`vv~re!es,s
`capabil:tv
`
`Timing of Acquiring media
`
`Data Transfer request is received
`
`Re<::eive request to
`t r onsfe:rthe alrea.dv
`createdNewMed~a
`FUe over t he pake-d
`connections.
`
`Re<:eive The New
`
`Capture Device and
`Store the New
`Media File
`
`short-raP.ge
`-~,il~re!ess
`capabl:itv
`
`,
`
`Earphone
`Dev;~
`
`Lin State Machine
`
`d to capture Te.:lliP'er:atur: .......
`Sta,.t Co-m~:~ ,.,.........
`, ... ,....
`,...._ .... ,
`~ ........... ~
`.. .......... ~
`...................... ....:
`
`temperature. (00201
`Un
`
`Tlmin~ for Acqu iring
`data isAftN
`re~etv~ng tht:
`"Start Command"
`
`44
`
`Canon Exhibit 1002, Page 215
`
`

`

`Fifth Argument: Transfer of already acquired new-media file over a pre-established
`
`short-range paired wireless connection
`
`Claim 1 discloses that the already acquired new-media file is transferred to the
`
`cellular phone, over the pre-established short-range paired wireless connection.
`
`The office action on pages 7-8 states that paragraph [0020] of Kennedy discloses
`
`this step. Applicant respectfully disagrees for the following reasons.
`
`Paragraph [0020] of Kennedy discloses: "The portable electronic device permits
`
`a user to take data that is acquired and or stored in the device and offload the data to an
`
`external remotely coupled device to make room for more data in the portable electronic
`
`device. For example, pictures in a digital camera can be offloaded to a web-based server
`
`through the user's cell phone."
`
`Nowhere in paragraph [0020] or elsewhere does Kennedy disclose that the digital
`
`camera device performs the following step: "Transferring the already existing new(cid:173)
`
`media file to the cellular phone, over the pre-established short-range paired wireless
`
`connection, where the cellular phone is configured to receive the transferred new-media
`
`file."
`
`Kennedy does not teach or suggest the digital camera device performs the
`
`method steps in the order given below:
`
`(a) Establishing a short-range paired wireless connection between the digital
`
`camera device and the cellular phone,
`
`(b) Acquiring new-media by the digital camera device, after establishing a short(cid:173)
`
`range paired wireless connection,
`
`45
`
`Canon Exhibit 1002, Page 216
`
`

`

`(c) Receiving a data transfer request initiated by a software application on the
`
`cellular phone that initiates the transfer of already existing New-Media file to
`
`the cellular phone, and only then
`
`(d) Transfer the already existing new-media file to the cellular phone over the
`
`pre-established short-range paired wireless connection.
`
`The office action on page 6 states that paragraphs [0020], [0023]-[0025] of Lin
`
`disclose this step. Applicant respectfully disagrees for the following reasons.
`
`None of the cited paragraphs in Lin teach or suggest the earphone performing the
`
`following steps:
`
`(a) Establishing a short-range paired wireless connection with the cellular phone,
`
`(b) Acquiring new temperature measurements, after establishing a short-range
`
`paired wireless connection,
`
`(c) Receiving a data transfer request from the cellular phone, where the data
`
`transfer request initiates the transfer of already existing temperature
`
`measurements to the cellular phone, and only then
`
`(d) Transferring the pre-acquired temperature measurements to the cellular phone
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`over the pre-established short-range paired wireless connection.
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`Hardman also does not teach or suggest the digital camera device performing the
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`method steps in the order listed above.
`
`Therefore, Kennedy in view of Lin and Hardman does not teach or suggest the
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`following limitation in amended claim 1:
`
`46
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`Canon Exhibit 1002, Page 217
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`

`

`"transferring the new-media file to the cellular phone, over the established short(cid:173)
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`range paired wireless connection, wherein the cellular phone is configured to
`
`receive the new-media file ... "
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`Sixth Argument: Using HTTP to transfer received new-media file and user
`
`information from a cellular phone to a website
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`Claim 1 discloses that the digital camera device together with the software
`
`application on the cellular phone performs the following steps (see FIG. 1 of the original
`
`application):
`
`Step 103: Establishing a short-range paired wireless connection between the
`
`digital camera device and the cellular phone.
`
`Step 104: New-media is acquired by the digital camera device.
`
`Step 105: Detection of new-media by the cellular phone and sending the data
`
`transfer request to the cellular phone that initiates the transfer of the already existing new(cid:173)
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`media file to the cellular phone.
`
`Step 106: Transfer of already existing new-media file from the digital camera
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`device to the cellular phone.
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`Only after the above steps, the cellular phone performs:
`
`Step 107: Use HTTP to transfer the received new-media and user information to
`
`the website over the cellular data network (see page 16, lines 15-17 of the original
`
`application: "The transport protocol that is used between the client application 203 and
`
`the publishing service 401 may be hypertext transfer protocol (HTTP) ... ")
`
`47
`
`Canon Exhibit 1002, Page 218
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`

`

`Page 8 of the office action states that paragraph [0020] of Kennedy discloses this
`
`step. Applicant respectfully disagrees for the following reasons.
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`Kennedy does not disclose HTTP.
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`Paragraph [0020] of Kennedy discloses: "The portable electronic device permits
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`a user to take data that is acquired and or stored in the device and offload the data to an
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`external remotely coupled device to make room for more data in the portable electronic
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`device. For example, pictures in a digital camera can be offloaded to a web-based server
`
`through the user's cell phone."
`
`Nowhere in paragraph [0020] does Kennedy teach or suggest that the camera
`
`performs the steps 103-106 in sequence before performing step 107. In other words,
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`Kennedy does NOT teach or suggest transfer of new-media and user information from
`
`the cellular phone to the website using Hyper Text Transfer Protocol (HTTP). There is
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`NO mention of HTTP or Hyper Text Transfer Protocol in Kennedy.
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`The office action page 9 states that paragraphs [0030] and [0036] of Hardman
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`teaches a HTTP request comprising user information and received new-media. Applicant
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`respectfully disagrees for the following reasons.
`
`Paragraph [0030] of Hardman discloses: "A request in the HTTP protocol can be
`
`made in a post request, the browser supplies the URL and additional information, such as
`
`a user name and password appended to the URL. In most cases, the additional
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`information is information that a user entered into an HTML form."
`
`Paragraph [0036] of Hardman discloses: "In an embodiment, such systems and
`
`methods provide for application software running on access device 150, such as a photo
`
`uploader, to access content servers 110, 120 and upload a desired photograph. Prior to
`
`accessing content servers 110, 120 a user associated with access device 150 is
`
`48
`
`Canon Exhibit 1002, Page 219
`
`

`

`authenticated to content servers 110, 120 and/or authorized to access the desired content
`
`server."
`
`Hardman argument 1: "Native media" vs "wirelessly transferred media"
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`Applicant discloses that the cellular phone is configured to transfer the "received
`
`new-media and user information" to a remote website using HTTP over the cellular
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`data network. In applicant's method, the cellular phone receives the new-media from a
`
`digital camera device over an established short-range paired wireless connection.
`
`Hardman does NOT teach wirelessly receiving new-media from another
`
`wirelessly connected device (digital camera device), combining that with user
`
`information, and sending both of them to the website. In contrast, Hardman discloses,
`
`inter alia, that the HTTP is applied to data that is native to the computer.
`
`In Hardman, the HTTP is NOT applied to media that is "received from a
`
`digital camera device over an established short-range paired wireless connection", or for
`
`that matter any wireless link.
`
`The difference between native vs received (non-native) data may be
`
`illustrated as follows:
`
`Consider an example of a PC connected to a normal home wireless router. In
`
`every day scenario, the PC attaches a hypertext transfer protocol (HTTP) header and user
`
`information to the Data generated by the PC (native media). In contrast, in applicant's
`
`method, the cellular phone is configured to send received new-media (non-native media)
`
`combined with user information stored on the cellular phone to the website. In applicant's
`
`method, the cellular phone is acting as more than just a normal home wireless router.
`
`Home Wireless routers do not "apply HTTP and combine user information store on the
`
`wireless router to the data received from the PC".
`
`49
`
`Canon Exhibit 1002, Page 220
`
`

`

`In applicant's method, the short-range wireless pairing established is therefore
`
`very important for non-native media that is acquired by a physically separate device and
`
`then transferred to the cellular phone over the trusted paired wireless connection.
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`Hardman argument 2: "Using a Web Browser on a PC for native media" vs "Using
`
`a software application running on a cellular phone for wirelessly received data".
`
`In applicant's method, for new-media received by the cellular phone, the user is
`
`not filling out the web-browser based HTTP web form to attach user information to the
`
`received new-media before the cellular phone sends that data to the website.
`
`In Hardman, attaching user information is done by filling out a web page on a
`
`browser running on a PC. In applicant's method, the software application (not the
`
`browser) on a much smaller cellular phone with cellular connection (not a PC) is
`
`attaching the user information.
`
`Further, Hardman either singly or in combination with Kennedy and Lin does not
`
`teach or suggest performing the steps 103-106 in the sequence shown above, before
`
`performing step 107.
`
`Therefore, Kennedy in view of Lin and Hardman does not teach or suggest the
`
`following limitation in amended claim 1:
`
`"t