IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Control No.
`Patent No.
`Filed
`
`: 95/001,912
`: 7,868,912
`: February 29, 2012
`
`Art Unit
`Examiner
`Cont. No.
`Atty. No.
`
`: 3992
`: Joshua D. Campbell
`: 1028
`: 4079-102
`
`Title: VIDEO SURVEILLANCE SYSTEM EMPLOYING VIDEO PRIMITIVES
`
`Mail Stop Inter Partes Reexam
`Central Reexamination Unit
`Commissioner for Patents
`United States Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`AMENDMENT AND REPLY
`
`This Amendment and Reply is in response to the non-final Office Action dated April 10,
`
`2012.
`
`Amendments to the Claims begin on page 2 of this paper.
`
`A Listing of the Status of Claims and Support for the New Claims begins on page 18 of
`
`this paper.
`
`Remarks begin on page 19 of this paper.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims-A
`
`Amendments to the Claims
`
`Pursuant to 37 CFR 1.530 ( d)(2) and (f)(2), please add the following proposed new
`
`claims:
`
`23.
`
`(New) The video system of claim 1, further comprising a computer having multiple
`
`processors, wherein the multiple processors include the first and second processors.
`
`24.
`
`(New) A distributed video computer system comprising:
`
`a first computer having a first processor;
`
`a second computer having a second processor, the second computer being connected to
`
`the first computer via a network;
`
`wherein the first processor analyzes a video to determine attributes of objects detected in
`
`the video. the first processor being in communication with the network to transfer the determined
`
`attributes over the network; and
`
`wherein the second processor is separate from the first processor, is in communication
`
`with the network to receive the determined attributes transferred from the first processor over the
`
`network, determines a first event that is not one of the determined attributes by analyzing a
`
`combination of the received determined attributes. and provides. in response to a determination
`
`of the first event, at least one of an alert to a user, information for a report, and an instruction for
`
`taking an action.
`
`wherein the first processor determines attributes independent of a selection of the first
`
`event by the second processor, and
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims -B
`
`wherein the second processor determines the first event without reprocessing the video
`
`analyzed by the first processor.
`
`25.
`
`(New) A distributed video computer system comprising:
`
`a first computer having a first processor;
`
`a second computer having a second processor. the second computer being connected to
`
`the first computer via a network;
`
`wherein the first processor is configured to analyze a video. to determine attributes of
`'
`
`objects detected in the video, and to transfer the determined attributes over the network; and
`
`wherein the second processor is separate from the first processor and is configured to
`
`receive the determined attributes transferred from the first processor over the network. to analyze
`
`a combination of the received determined attributes. to determine a first event that is not one of
`
`the determined attributes, and to provide, in response to a determination of the first event, at least
`
`one of an alert to a user. information for a report, and an instruction for taking an action.
`
`wherein the determining of attributes by the first processor is independent of the
`
`determination of the first event by the second processor, and
`
`wherein the determining of the first event by the second processor is without reprocessing
`
`the video analyzed by the first processor.
`
`26.
`
`(New) A video system comprising:
`
`a first computer-readable medium;
`
`a computer including:
`
`a second computer-readable medium;
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims - C
`
`a first processor which analyzes a video to determine attributes of objects detected
`
`in the video, the first processor being in communication with a first communications link
`
`to transfer the determined attributes over the communications link and archive the
`
`determined attributes in the first computer-readable medium; and
`
`a second processor, separate from the first processor, in communication with the
`
`first communications link to receive the determined attributes transferred from the first
`
`processor over the first communications link and archived in the first computer readable
`
`medium. which de.termines a first event that is not one of the determined attributes by
`
`analyzing a combination of the received determined attributes and which provides. in
`
`response to a·dete~ination of the first event, at least one of an alert to a user.
`
`information for a report. and an instruction for taking an action,
`
`wherein the first processor determines attributes independent of a selection of the first
`
`event by the second processor, and
`
`wherein the second processor determines the first event without reprocessing the video
`
`analyzed by the first processor.
`
`27.
`
`(New) The video system of claim 26. wherein the first computer-readable medium is
`
`configured to transmit and receive data via the first communications link.
`
`28.
`
`(New) The video system of claim 26. wherein the first communications link comprises a
`
`network.
`
`29.
`
`(New) A video system, comprising:
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims-D
`
`a computer-readable medium in communication with a communications channel, the
`
`computer-readable medium archiving detected attributes;
`
`an input in communication with the communications channel;
`
`a urocessor configured to receive from the input a stream of the detected attributes
`
`received over the communications channel from the computer-readable medium, the received
`
`attributes being attributes of one or more objects detected in a video. the processor configured to
`
`determine an event that is not one of the detected attributes by analyzing a combination of the
`
`received attributes and configured to provide. upon a determination of the event, at least one of
`
`an alert to a user. information for a report and an instruction for taking an action,
`
`wherein the attributes received over the communications channel are independent of the
`
`event to be determined by the processor, and
`
`wherein the processor is configured to determine the event without reprocessing the
`
`30.
`
`(New) The video system of claim 29, wherein the communications channel comprises a
`
`network.
`
`31.
`
`(New) A video system, comprising:
`
`a computer-readable medium archiving detected attributes;
`
`a processor configured to receive a stream of the detected attributes from the computer-
`
`readable medium via a communications channel, to analyze a combination of the received
`
`determined attributes. to determine an event that is not one of the detected attributes. and to
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims -E
`
`provide, upon a determination of the event. at least one of an alert to a user, information for a
`
`report and an instruction for taking an action,
`
`wherein the received attributes are attributes of one or more objects detected in a video,
`
`wherein the attributes received over the communications channel are independent of the
`
`event to be determined lJy the processor, and
`
`wherein the processor is configured to determine the event without reprocessing the
`
`32.
`
`(New) The video system of claim 31, wherein the communications channel comprises a
`
`network.
`
`33.
`
`(New) The video system of claim 31, wherein the computer-readable medium is
`
`configured to transmit and receive data via the communications channel.
`
`34.
`
`(New) A method of detecting an event from a video, comprising:
`
`archiving detected attributes in a computer-readable medium, the detected attributes
`
`representing attributes of an object previously detected in the video at a remote location;
`
`receiving a stream of th.e detected attributes from the computer-readable medium over a
`
`communications channel;
`
`performing an analysis of a combination of the archived and received detected attributes
`
`to detect an event that is not one of the detected attributes without reprocessing the video.
`
`upon detecting the event, providing at least one of an alert to a user, information for a
`
`report and an instruction for ~aking an action,
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims - F
`
`wherein the detected attributes received in the stream of attributes are independent of a
`
`selection of the event to be detected.
`
`35.
`
`(New) The method of claim 34, wherein the communications channel comprises a
`
`network.
`
`36.
`
`(New) The video system of claim 34, wherein the computer-readable medium is
`
`configyred to transmit and receive data via the communications channel.
`
`37.
`
`(New) A method comprising:
`
`analyzing a video to detect an object;
`
`creating a stream of attributes at a first location by determining attributes of the detected
`
`object by analyzing the video;
`
`transmitting the stream of attributes to a second location removed from the first location
`
`for archiving in a computer-readable medium at the second location and subsequent analysis.
`
`wherein the stream of attributes are transmitted to the second location over a
`
`communications channel, and
`
`wherein the stream of attributes is sufficient to allow the subsequent analysis to detect an
`
`event of the video to provide at least one of an alert to a user, information for a report and an
`
`instruction for taking an action, the event not being one of the determined attributes.
`
`'
`
`.
`
`wherein the stream of attributes is sufficient to allow detection of the event that is not one
`
`of the determined attributes without reprocessing the video of the first location.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims - G
`
`38.
`
`(New) The method of claim 37. wherein the communications channel comprises a
`
`network.
`
`39.
`
`(New) The method of claim 37, further comprising archiving the determined attributes in
`
`a computer-readable medium at the second location.
`
`40.
`
`(New) The method of claim 39. further comprising:
`
`receiving the archived determined attributes from the computer-readable medium via the
`
`communications channel; and
`
`analyzing a combination of the received determined attributes to detect the event of the
`
`video. the event not being one of the determined attributes.
`
`41.
`
`(New) The method of claim 40. further comprising:
`
`upon detecting the event. providing at least one of an alert to a user. information for a
`
`report. and an instruction for taking an action.
`
`42.
`
`(New) A video device. comprising:
`
`a processor at a first location which analyzes a video to detect an object and to determine
`
`attributes of the object detected in the video;
`
`an output configured to transmit the attributes determined by the processor over a
`
`communications link.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims-H
`
`wherein the output is configured to transmit the attributes to a second location removed
`
`from the processor for archiving the attributes in a computer-readable medium at the second
`
`location and for a subsequent analysis of a combination of the attributes at the second location,
`
`wherein the processor determines attributes independently of a subsequent analysis of a
`
`combination of attributes to determine an event that is not one of the determined attributes, and
`
`wherein the attributes are sufficient to allow detection of an event to provide at least one
`
`of an alert to a user, information for a report and an instruction for taking an action, the event not
`
`being one of the determined attributes and being determinable by analyzing the combination of
`
`the attributes,
`
`wherein the attributes are sufficient to allow detection of an event without reprocessing
`
`the video of the first location.
`
`43.
`
`(New) The video device of claim 42, wherein the communications link comprises a
`
`network.
`
`44.
`
`(New) A video device, comprising:
`
`a processor at a first location configured to analyze a video to detect an object and to
`
`determine attributes of the object detected in the video:
`
`an output configured to transmit the attributes determined by the processor over a
`
`communications link,
`
`wherein the output transmits the attributes to a second location removed from the first
`
`location and is further configured to archive the attributes in a computer-readable medium at the
`
`second location and to analyze a combination of the attributes at the second location,
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims - I
`
`wherein the processor is further configµred to determine attributes independently of a
`
`subsequent analysis of a combination of attributes to determine an event that is not one of the
`
`determined attributes, and
`
`wherein the attributes are sufficient to allow detection of an event to provide at least one
`
`of an alert to a user, information for a report and an instruction for taking an action, the event not
`
`being one of the determined attributes and being determinable by analyzing the combination of
`
`the attributes,
`
`wherein the attributes are sufficient to allow detection of an event without reprocessing
`
`the video of the first location.
`
`45.
`
`(New) The video device of claim 44, wherein the communications link comprises a
`
`network.
`
`46.
`
`(New) The video system of claim 1, wherein each of the attributes of the objects is an
`
`observable characteristic of an object, and the first event is one or more of the objects engaged in
`
`an activity.
`
`47.
`
`(New) The video system of claim 46, wherein the attributes include at least one temporal
`
`attribute.
`
`48.
`
`(New) The video system of claim 47, wherein the attributes include at least one spatial
`
`attribute.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims -J
`
`49.
`
`(New) The video system of claim 46, wherein the attributes include at least one spatial
`
`attribute.
`
`50.
`
`(New) The video system of claim 46, wherein the attributes include a color of an object.
`
`51.
`
`(New) The video system of claim 46, wherein the attributes include a size of an object.
`
`52.
`
`(New) The video system of claim 46, wherein the attributes include at least one of a
`
`velocity and a speed of an object.
`
`53.
`
`(New) The video system of claim 46, wherein the attributes include a position of an
`
`object.
`
`54.
`
`(New) The video system of claim 46, wherein the attributes include a trajectory of an
`
`object.
`
`55.
`
`(New) The video system of claim 46, wherein the attributes include a classification of an
`
`object.
`
`56.
`
`(New) The video system of claim 46, wherein the attributes include a shape of an object.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims-K
`
`57.
`
`(New) The video system of claim 6, wherein each of the attributes of the one or more
`
`objects is an observable characteristic of an object, and the event is one or more objects engaged
`
`in an activity.
`
`58.
`
`(New) The video system of claim 57, wherein the attributes include at least one temporal
`
`attribute.
`
`59.
`
`(New) The video system of claim 58, wherein the attributes include at least one spatial
`
`attribute.
`
`60.
`
`(New) The video system of claim 57, wherein the attributes include at least one spatial
`
`attribute.
`
`61.
`
`· (New) The video system of claim 57, wherein the attributes include a color of an object.
`
`62.
`
`(New) The video system of claim 57, wherein the attributes include a size of an object.
`
`63.
`
`(New) The video system of claim 57, wherein the attributes include at least one of a
`
`velocity and a speed of an object.
`
`64.
`
`(New) The video system of claim 57, wherein the attributes include a position of an
`
`object.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims - L
`
`65.
`
`(New) The video system of claim 57, wherein the attributes include a trajectory of an
`
`object.
`
`66.
`
`(New) The video system of claim 57, wherein the attributes include a classification of an
`
`object.
`
`67.
`
`(New) The video system of claim 57, wherein the attributes include a shape of an object.
`
`68.
`
`(New) The method of claim 9, further comprising the step of determining the attributes of
`
`the object detected in the video prior to the step of performing the analysis of the combination of
`
`the detected attributes to detect the event.
`
`69.
`
`(New) The method of claim 9, wherein each of the attributes of the object is an
`
`observable characteristic of the object, and the event is one or more objects engaged in an
`
`activity.
`
`70.
`
`(New) The method of claim 69, wherein the attributes include at least one temporal
`
`attribute.
`
`71.
`
`(New) The method of claim 70, wherein the attributes include at least one spatial
`
`attribute.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims-M
`
`72.
`
`(New) The method of claim 69, wherein the attributes include at least one spatial
`
`attribute.
`
`73.
`
`(New) The method of claim 69. wherein the attributes include a color of the object.
`
`74.
`
`(New) The method of claim 69. wherein the attributes include a size of the object.
`
`75.
`
`(New) The method of claim 69. wherein the attributes include at least one of a velocity
`
`and a speed of the object.
`
`76.
`
`(New) The method of claim 69. wherein the attributes include a position of the object.
`
`77.
`
`(New) The method of claim 69. wherein the attributes include a trajectory of the object.
`
`78.
`
`(New) The method of claim 69. wherein the attributes include a classification of the
`
`object.
`
`79.
`
`(New) The method of claim 69. wherein the attributes include a shape of the object.
`
`80.
`
`(New) The method of claim 12. wherein each of the attributes of the detected object is an
`
`observable characteristic of the detected object. and the event is one or more objects engaged in
`
`an activity.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims -N
`
`81.
`
`(New) The method of claim 80, wherein the attributes include at least one temporal
`
`attribute.
`
`82.
`
`(New) The method of claim 81. wherein the attributes include at least one spatial
`
`attribute.
`
`83.
`
`(New) The method of claim 80, wherein the attributes include at least one spatial
`
`attribute.
`
`84.
`
`(New) The method of claim 80. wherein the attributes include a color of the object.
`
`85.
`
`(New) The method of claim 80. wherein the attributes include a size of the object.
`
`86.
`
`(New) The method of claim 80. wherein the attributes include at least one of a velocity
`
`and a speed of the object.
`
`87.
`
`(New) The method of claim 80, wherein the attributes include a position of the object.
`
`88.
`
`(New) The method of claim 80. wherein the attributes include a trajectory of the object.
`
`89.
`
`(New) The method of claim 80. wherein the attributes include a classification of the
`
`object.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims -0
`
`90.
`
`(New) The method of claim 80. wherein the attributes include a shape of the object.
`
`91.
`
`(New) The video device of claim 18, wherein each of the attributes of the object is an
`
`observable characteristic of the object, and .the event is one or more objects engaged in an
`
`activity.
`
`92.
`
`(New) The method of claim 91, wherein the attributes include at least one temporal
`
`attribute.
`
`93.
`
`(New) The method of claim 92. wherein the attributes include at least one spatial
`
`attribute.
`
`94.
`
`(New) The method of claim 91, wherein the attributes include at least one spatial
`
`attribute.
`
`95.
`
`(New) The method of claim 91, wherein the attributes include a color of the object.
`
`96.
`
`(New) The method of claim 91, wherein the attributes include a size of the object.
`
`97.
`
`(New) The method of claim 91, wherein the attributes include at least one of a velocity
`
`and a speed of the object.
`
`98.
`
`(New) The method of daim 91, wherein the attributes include a position of the object.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Claims - P
`
`99.
`
`(New) The method of claim 91, wherein the attributes include a trajectory of the object.
`
`100.
`
`(New) The method of claim 91, wherein the attributes include a classification of the
`
`object.
`
`101.
`
`(New) The method of claim 91, wherein the attributes include a shape of the object.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page2
`
`Status of Claims and Support for the Proposed New Claims
`
`Claims 1-4 and 6-22 are pending in this reexamination and have not been amended.
`
`Claims 23-101 are proposed to be added. Support for the proposed new claims is found in the
`
`specification of U.S. Patent No. 7,868,912 and in the specification of U.S. Patent Application
`
`No. 09/987,707, which was filed on November 15, 2001. See 37 C.F.R. § 1.132 Declaration of
`
`Dr. Kenneth A. Zeger Dec. ("Zeger Dec."), 1129 and the support claim chart appended to Dr.
`
`Zeger's declaration (App. Z3). In accordance with 37 CFR 1.530G), none of the requested new
`
`claims enlarges the scope of the patented claims or adds new matter.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page3
`
`I. Introduction
`
`Remarks
`
`U.S. Patent No. 7,868,912 (''the '912 patenf') is generally directed to systems, methods,
`
`and devices for video surveillance. See '912 patent, Abstract (U.S. Patent Application No.
`
`09/987,707 (''the '707 app."), Abstract1). The claimed systems, methods, and devices improve
`
`prior art video surveillance by separating the processes of (1) extracting attributes2 of objects
`
`detected in a video and (2) applying rules to those attributes to independently identify events.
`
`See Figs. 4 and 9 (Figs. 4 and 9). For example, Figure 4 of the '912 patent illustrates an
`
`embodiment that supports separating these two processes.
`
`42
`
`·§b~li
`lllOUICef
`Video
`
`.~·
`
`~ .. -~rf-
`
`i~
`· - - :re.tlflOMfK
`
`See Zeger Dec., ,r34,
`
`In the figure, block 42 represents the process of extracting attributes, in the form of video
`
`primitives, from the objects. See '912 patent at col. 18, lines 61-65 ('707 app. at ,r106). These
`
`primitives include observable characteristics of the objects. See col. 13, lines 14-16 ('707 app. at
`
`,rso). Separately, in block 44, event occurrences are identified by comparing those attributes to
`
`a set of event discriminators (i.e., rules) that facilitate "inference analysis" based on video
`
`primitives. See col. 5, lines 53-57 and col. 20, lines 35-40 ('707 app. at ,r,r67 & 118). See Zeger
`
`Dec., ,r35_
`
`1 To support Patent Owner's entitlement to its Nov. 15, 2001, priority date, each citation to the '912 patent also
`includes a citation to the Nov. 15, 2001, priority document in a parenthetical following the '912 patent citation. The
`priority document is included in Appendix A
`2 "Attributes are also called "primitives." Zeger Dec. at ,r24.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page4
`
`The power of this separation is that the identification of an event can be performed
`
`independent of the extraction of object attributes. Thus, the events do not need to be preset by
`
`the system at the time or location that the object attributes are extracted. As the inventors
`
`explained, "the system can perform inference analysis based on the previously recorded video
`
`primitives." '912 patent at col. 5, lines 54-55 ('707 app. at ,r67). See Zeger Dec., ,r36.
`
`Inferring events based on the attributes (or primitives) provides several advantages as
`
`described by the inventors. First, "[a]n operator is provided with maximum flexibility in
`
`configuring the system by using event discriminators." Col. 5, lines 28-29 ('707 app. at ,r66).
`
`Thus, an operator is not restricted by the prerecorded events extracted in the initial process of
`
`interpreting the video. Second, inference analysis based on previously extracted attributes
`
`"greatly improves the analysis speed of the computer system." Col. 5, lines 56-57 ('707 app. at
`
`%7). If the system can independently infer events from the attributes, then the system can
`
`process the attributes instead of reprocessing the video. Col. 5, lines 54-55 ('707 app. at ,r67).
`
`This results in very significant time savings. Third, inventing a system for analyzing "small(cid:173)
`
`sized video primitives abstracted from the video" has many corresponding size-based benefits.
`
`Col. 24, lines 48-50 ('707 app. at 1f148). For example, the storage space and bandwidth space
`
`necessary to manage the small-sized attributes is far less than the space for managing the video
`
`itself, even if the video is highly compressed. All of these benefits flow from the systems,
`
`methods, and devices claimed in the '912 patent that make the extraction of attributes
`
`independent from the events that the operator tasks the system to identify. See Zeger Dec., ,r36.
`
`On February 29, 2012, Bosch Security Systems, Inc. (the "Requester") submitted a
`
`Request for Inter Partes Reexamination ("the Request") of claims 1-22. On April 10, 2012, the
`
`Office granted the Request with respect to claims 1-4 and 6-22 and issued an Office Action ("the
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page5
`
`Office Action") rejecting all of these claims under 35 U.S.C. § 102(b). Patent Owner
`
`respectfully submits that the cited references do not anticipate the subject matter of any of the
`
`rejected claims of the '912 patent. Accordingly, all rejections are traversed, and reconsideration
`
`is respectfully requested.
`
`II. Claimed Invention
`
`The '912 patent describes and claims systems, methods, and devices for video
`
`surveillance using attributes of objects detected in a video. Claim 1 is representative of the
`
`present invention:
`
`A video system comprising:
`
`a first processor which analyzes a video to determine attributes of objects detected
`in the video, the first processor being in communication with a first
`communications link to transfer the determined attributes over the
`communications link; and
`
`a second processor, separate from the first processor, in communication with the
`first communications link to receive the determined attributes transferred from the
`first processor over the first communications link, which determines a first event
`that is not one of the determined attributes by analyzing a combination of the
`received determined attributes and which provides, in response to a determination
`of the first event, at least one of an alert to a user, information for a report, and an
`instruction for taking an action,
`
`wherein the first processor determines attributes independent of a selection of the
`first event by the second processor, and
`
`wherein the second processor determines the first event without reprocessing the
`video analyzed by the first processor.
`
`Claims 2-4 depend on claim 1 and contain additional limitations.
`
`Independent claims 6 and 9 focus on event determination while still other claims, such as
`
`independent claims 12 and 18, focus on attribute detection.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page6
`
`Claims 1-4 and 6-22 of the '912 patent all contain limitations that require that the
`
`attributes must be independent from the event to be identified as described above. The following
`
`claim elements (the "independence-based elements") incorporate this requirement:
`
`Claim Element
`which determines a first event that is not one of the determined
`attributes by analyzing a combination of the received determined
`attributes
`
`wherein the first processor determines attributes independent of a
`selection of the first event by the second processor
`
`Claims
`'912 patent, claims 1-4
`
`'912 patent, claims 1-4
`
`the processor configured to determine an event that is not one of the
`detected attributes by analyzing a combination of the received attributes
`
`'912 patent, claims 6-8
`
`wherein the attributes received over the communications channel are
`independent of the event to be determined by the processor
`
`'912 patent, claims 6-8
`
`performing an analysis of a combination of the detected attributes to
`detect an event that is not one of the detected attributes
`
`'912 patent, claims 9-
`11
`
`wherein the detected attributes received in the stream of attributes are
`independent of a selection of the event to be detected
`
`'912 patent, claims 9-
`11
`
`wherein the stream of attributes is sufficient to allow detection of the
`event that is not one of the determined attributes
`
`'912 patent, claims 12-
`17
`
`wherein the attributes of the stream of attributes are created
`independently of the subsequent analysis
`
`wherein the stream of attributes is sufficient to allow detection of an
`event that is not one of the determined attributes by analyzing a
`combination of the attributes
`
`'912 patent, claim 15
`
`'912 patent, claim 16
`
`wherein the stream of attributes is transmitted over a communications
`channel without detection of an event at the first location
`
`'912 patent, claim 17
`
`wherein the processor determines attributes independently of a
`subsequent analysis of a combination of attributes to determine an
`event that is not one of the determined attributes
`
`'912 patent, claims 18-
`22
`
`See Zeger Dec., ,r38.
`
`III. Summary of the Rejections
`
`The Office Action rejects each of the claims subject to reexamination, grouping these
`
`rejections into four sub-issues:
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page 7
`
`Issue 1 - Claims 1-3 and 6-22 in view of German Patent Publication No. DE 101 53 484
`Al to Gilge (Ex. 13 to the Request) ("Gilge")
`
`Issue 3 - Claims 1-4 and 6-22 in view of "ObjectVideo Forensics: Activity-Based Video
`Indexing and Retrieval For Physical Security Applications," Lipton et al. (Ex. 15
`to the Request) ("Lipton")
`
`Issue 5 - Claims 1, 3, 4, 6, 8, 9, 11-13, 15-20, and 22 in view of U.S. Patent No.
`5,969,755 to Courtney (Ex. 16 to the Request) ("Courtney '755")
`
`Issue 12-Claims 1, 3, 4, 6, 8, 9, 11-13, 15-20, and 22 in view of "Moving Object
`Detection and Event Recognition Algorithms for Smart Cameras," Olson et al.
`(Ex. 20 to the Request) ("Olson")
`
`The Office incorporates by reference the arguments of the Request in support of each rejection.
`
`See Office Action, pp. 4-5. Accordingly, responsive arguments and specific citations will be
`
`made with respect to both the Office Action and the Request.
`
`Each of the bases for rejection is addressed by Dr. Zeger3 and summarized below. See
`
`Zeger Dec., 1f1f21-73.
`
`IV. Anticipation Reiections
`
`A. Issues 1 and 3
`
`Claims 1-3 and 6-22 stand rejected under 35 U.S.C. § 102(b) as allegedly anticipated by
`
`Gilge (Issue 1). In addition, claims 1-4 and 6-22 stand rejected under 35 U.S.C. § 102(b) as
`
`allegedly anticipated by Lipton (Issue 3). Patent Owner respectfully submits that Gilge and
`
`Lipton are not prior art under 35 U.S.C. § 102(b). Thus, reconsideration of these rejections is
`
`respectfully requested.
`
`3 As explained in detail in 11112-11 of the Zeger Declaration, Dr. Zeger is an expert in the field qualified to testify
`regarding the relevant art, the level of ordinary skill in the art, and what would or would not have been obvious to a
`person of ordinary skill in the art.
`
`

`

`Attorney Docket No. 4079-102
`Control No. 95/001,912
`Page 8
`
`1. Claims 1-4 and 6-22 of the '912 Patent are Entitled to the Benefit of the
`November 15, 2001, Filing Date
`
`The '912 patent was granted on U.S. Patent Application Serial No. 11/098,385, which is
`
`a continuation-in-part of U.S. Patent Application Serial No. 11/057,154, filed on February 15,
`
`2005, which is a continuation-in-part of U.S. Patent Application Serial No. 09/987,707 ("the
`
`'707 application"), filed on November 15, 2001. Claims 1-4 and 6-22 of the '912 patent are
`
`entitled to the priority date of at least November 15, 2001.
`
`Claims of an application that is a continuation-in-part of an earlier U.S. application or
`
`international application "which are fully supported under 35 U.S.C. 112 by the earlier parent
`
`application have the effective filing date of that earlier parent application." MPEP
`
`§ 706.02(Vl)(B). See also 35 U.S.C. § 120 ("An application disclosed in the manner provided
`
`by the first paragraph of section 112 of this title in an application previously filed in the United
`
`States ... shall have the same effect, as to such invention, as though filed on the date of the prior
`
`application ... "). A claim is adequately disclosed/fully supported under 35 U.S.C. § 112 by an
`
`earlier parent application if the earlier application satisfies the written description requirement
`
`for that claim. See MPEP § 2163(1).
`
`"To satisfy the written description requirement, a patent specification must describe