throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`: 90/012,878
`: 7,868,912
`Patent No.
`: May 24, 2013
`Filed
`Customer No. : 06449
`
`Art Unit
`Examiner
`Conf. No.
`Atty. No.
`
`: 3992
`: Adam L. Basehoar
`: 3806
`: 4079-117
`
`Title: VIDEO SURVEILLANCE SYSTEM EMPLOYING VIDEO PRIMITIVES
`
`Mail Stop Ex Parte Reexam
`Central Reexamination Unit
`Commissioner for Patents
`United States Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`RECEIVED
`OCT 3 0 2013
`
`CENTRAL REEXAMINATION UNIT
`
`AMENDMENT AND REPLY
`
`This Amendment and Reply ("Reply") is in response to the non-final Office Action dated
`
`August 30, 2013.
`
`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 12 of
`
`this paper.
`
`Remarks begin on page 13 of this paper.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page2
`
`Amendments to the Claims
`
`Pursuant to 37 CFR 1.530 (d)(2) and (f)(2), please cancel claim 5 and add the following
`
`proposed new claims:
`
`5.
`
`(Canceled)
`
`23.
`
`(New) 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 analyzing the combination of the
`
`received determined attributes comprises filtering,
`
`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.
`
`24.
`
`(New) A video system, comprising:
`
`an input in communication with a communications channel;
`
`a processor configured to receive from the input a stream of detected attributes received
`
`over the communications channel, the 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
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 3
`
`instruction for taking an action. wherein analyzing the combination of the received attributes
`
`comprises filtering.
`
`wherein the attributes received over the communications channel are inde_pendent of the
`
`event to be determined by the processor. and
`
`wherein the processor is configured to determine the event without re.processing the video.
`
`25.
`
`(New) A method of detecting an event from a video. comprising:
`
`receiving a stream of detected attributes over a communications channel. the detected
`
`attributes re.presenting attributes of an object previously detected in the video at a remote
`
`location:
`
`performing an analysis of a combination of the detected attributes to detect an event that
`
`_is not one of the detected attributes without reprocessing the video. wherein the analysis of the
`
`combination of the detected attributes comprises filtering.
`
`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.
`
`wherein the detected attributes received in the stream of attributes are inde_pendent of a
`
`· selection of the event to be detected.
`
`26.
`
`(New) 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 attributes of objects detected in t~e video comprise first and second objects.
`
`and the first event is the first and second objects coming together.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 4
`
`wherein the first processor detennines attributes independent of a selection of the first
`
`event by the second processor, and
`
`wherein the second processor detennines the first event without reprocessing the video
`
`analyzed by the first processor.
`
`27.
`
`(New) A video system, comprising:
`
`an input in communication with a communications channel;
`
`a processor configured to receive from the input a stream of detected attributes received
`
`over the communications channel, the attributes being attributes of first and second objects
`
`detected in a video, the processor configured to detennine an event that is not one of the detected
`
`attributes by analyzing a combination of the received attributes and configured to provide, upon
`
`a detennination of the event, at least one of an alert to a user, infonnation for a report and an
`
`instruction for taking an action, the event being the first and second objects coming together,
`
`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 video.
`
`28.
`
`(New) A method of detecting an event from a video, comprising:
`
`receiving a stream of detected attributes over a communications channel, the detected
`
`attributes representing attributes of first and second objects previously detected in the video at a
`
`remote location;
`
`performing an analysis of a combination of the detected attributes to detect an event that
`
`is not one of the detected attributes without reprocessing the video, the event being the first and
`
`second objects coming together,
`
`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.
`
`wherein the detected attributes received in the stream of attributes are independent of a
`
`selection of the event to be detected.
`
`29.
`
`(New) A method comprising:
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 5
`
`analyzing a video to detect first and second objects;
`
`creating a stream of attributes at a first location by determining attributes of the detected
`
`first object and attributes of the detected second object by analyzing the video;
`
`transmitting the stream of attributes to a second location removed from the first location
`
`for 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, the event
`
`being the first and second objects coming together,
`
`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.
`
`30.
`
`(New) A video device, comprising:
`
`a processor at a first location which analyzes a video to detect first and second objects
`
`and to determine attributes of the first object detected in the video and attributes of the second
`
`object detected in the video;
`
`an output configured to transmit the attributes determined by the processor over a
`
`communications link,
`
`wherein the output is configured to transmit the attributes to a second location removed
`
`from the processor 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, the
`
`event being the first and second objects coming together, 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,
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page6
`
`wherein the attributes are sufficient to allow detection of an event without reprocessing
`
`the video of the first location.
`
`31.
`
`<New) 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 analyzing the combination of the
`
`received determined attributes comprises filtering,
`
`wherein the attributes of objects detected in the video comprise first and second objects,
`
`and the first event is the first and second objects coming together,
`
`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.
`
`32.
`
`<New) A video system, comprising:
`
`an input in communication with a communications channel;
`
`a processor configured to receive from the input a stream of detected attributes received
`
`over the communications channel, the attributes being attributes of first and second 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 analyzing the combination of the received attributes
`
`comprises filtering,
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page7
`
`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 video.
`
`33.
`
`(New) A method of detecting an event from a video. comprising:
`
`receiving a stream of detected attributes over a communications channel, the detected
`
`attributes representing attributes of first and second objects previously detected in the video at a
`
`remote location:
`
`performing an analysis of a combination of the detected attributes to detect an event that
`
`is not one of the detected attributes without reprocessing the video, wherein the analysis of the
`combination of the detected attributes comprises filtering, the event being the first and second
`
`objects coming together,
`
`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.
`
`wherein the detected attributes received in the stream of attributes are independent of a
`
`selection of the event to be detected.
`
`34.
`
`(New) 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,
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 8
`
`wherein the second processor determines the first event without reprocessing the video
`
`analyzed by the first processor, and
`
`wherein none of the determined attributes refers to the object engaged in an activity.
`
`35.
`
`(New) A video system, comprising:
`
`an input in communication with a communications channel;
`
`a processor configured to receive from the input a stream of detected attributes received
`
`over the communications channel, the 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 detennination 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,
`
`wherein the processor is configured to determine the event without reprocessing the video,
`
`wherein none of the detected attributes refers to the one or more objects engaged in an
`
`activity.
`
`36.
`
`(New) A method of detecting an event from a video, comprising:
`
`receiving a stream of detected attributes over a communications channel, the detected
`
`attributes representing attributes of an object previously detected in the video at a remote
`
`location;
`
`performing an analysis of a combination of the 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 taking an action.
`
`wherein the detected attributes received in the stream of attributes are independent of a
`
`selection of the event to be detected, and
`
`wherein none of the detected attributes refers to the object engaged in an activity.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page9
`
`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 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, and
`
`wherein none of the determined attributes refers to the object engaged in an activity.
`
`38.
`
`(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,
`
`wherein the output is configured to transmit the attributes to a second location removed
`
`from the processor 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,
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 10
`
`wherein the attributes are sufficient to allow detection of an event without reprocessing
`
`the video of the first location, and
`
`wherein none of the determined attributes refers to the object engaged in an activity.
`
`39.
`
`(New) 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 detennines a first event that is not one of the determined
`
`attributes by analyLing a combination of the received determined attributes and which provides,
`
`in response to a detennination 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 analyzing the combination of the
`
`received determined attributes comprises filtering,
`
`wherein the first processor determines attributes independent of a selection of the first
`
`event by the second processor,
`
`wherein the second processor determines the first event without reprocessing the video
`
`analyzed by the first processor, and
`
`wherein none of the determined attributes refers to the object engaged in an activity.
`
`40.
`
`(New) A video system, comprising:
`
`an input in communication with a communications channel;
`
`a processor configured to receive from the input a stream of detected attributes received
`
`over the communications channel, the 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 analyzing the combination of the received attributes.
`
`comprises filtering,
`
`

`

`Attorney Docket No. 4079•1 l 7
`Control No. 90/012,878
`Page 11
`
`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 video.
`
`wherein none of the detected attributes refers to the one or more objects engaged in an
`
`activity.
`
`41.
`
`<New) A method of detecting an event from a video. comprising:
`
`receiving a stream of detected attributes over a communications channel, the detected
`
`attributes representing attributes of an object previously detected in the video at a remote
`
`location;
`
`performing an analysis of a combination of the detected attributes to detect an event that
`
`is not one of the detected attributes without reprocessing the video, wherein the analysis of the
`
`combination of the detected attributes comprises filtering,
`
`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,
`
`wherein the detected attributes received in the stream of attributes are independent of a
`
`selection of the event to be detected, and
`
`wherein none of the detected attributes refers to the object engaged in an activity.
`
`42.
`
`The video system of claim 23, wherein the filtering comprises filtering the combination
`
`of the received determined attributes to determine if the first event occurred.
`
`43.
`
`The video system of claim 24, wherein the filtering comprises filtering the combination
`
`of the received attributes to determine if the event occurred.
`
`44.
`
`The method of claim 25, wherein the filtering comprises filtering the combination of the
`
`detected attributes to determine if the event occurred.
`
`

`

`Attorney Docket No. 4079-11 7
`Control No. 90/012,878
`Page 12
`
`Status of Claims and Support for the Proposed New Claims
`
`Claims 1-22 are pending in this reexamination. No amendments to claims 1-4 and 6-22
`
`have been proposed. Cancellation of claim 5 and addition of claims 23-44 has been proposed.
`
`In accordance with 37 C.F.R. § l.530(j), none of the requested new claims enlarges the scope of
`
`the patented claims or adds new matter. Support for the proposed new claims is found
`
`throughout the specifications of U.S. Patent No. 7,868,912 and U.S. Patent Application No.
`
`09/987,707, filed on November 15, 2001. See 37 C.F.R. § 1.132 Declaration of Dr. Kenneth A.
`
`Zeger Dec. ("Zeger Dec."), 1159-65. Patent Owner respectfully requests entry of the proposed
`
`amendments. Upon entry of the proposed amendments, claims 1-4 and 5-44 will be pending.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 13
`
`I.
`
`Introduction
`
`Remarks
`
`U.S. Patent No. 7,868,912 ("the '912 patent"), 1 entitled "Video Surveillance System
`
`Employing Video Primitives," is generally directed to methods, devices, and computer-readable
`
`storage media for video surveillance. See U.S. Patent Application No. 09/987,707 ("the '707
`
`application"), Abstract.2 The claimed methods, devices, and computer-readable storage media
`
`improve prior art video surveillance by separating the processes of ( 1) extracting attributes of
`
`objects (i.e., primitives) detected in a video and (2) applying rules to those attributes to
`
`independently identify events. See '707 application at Figs. 4 & 9. For example, Figure 4
`
`illustrates an embodiment that supports separating these two processes.
`
`41
`
`42
`
`43
`
`44
`
`45
`
`obtain
`source
`video
`
`:extract
`video
`primitives
`
`ari::tiive
`video·
`primjtiyes
`
`FIG.4
`
`extract
`event
`occurrences
`
`undertake.
`1'8$pol'.l$8,
`as appropriate
`
`Block 42 represents the process of extracting attributes, in the form of video primitives,
`from the objects. See '707 application at ,r 106. These primitives include observable
`characteristics of the objects. See id. at ,r 80. 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 id. at ,r,r 67 & 118.
`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. "[T]he system can
`
`perform inference analysis based on the previously recorded video primitives." '707 application
`at ,r 67.
`
`1 The '912 patent is a continuation-in-part ("CIP") of U.S. Patent Application No. 09/987,707,
`filed on Feb. 15, 2005, which is a CIP of U.S. Patent Application No. 09/987,707 ("the '707
`application"), filed on Nov. 15, 2001 (Exhibit RI).
`2 To support Patent Owner's entitlement to its Nov. 15, 200 I, priority date, each citation to the
`specification of the '912 patent refers to the '707 application, which is incorporated by reference
`in the '912 patent. '912 patent, col. 1, line 12.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 14
`
`Inferring events based on the attributes (or primitives) provides several advantages. First,
`
`"[a]n operator is provided with maximum flexibility in configuring the system by using event
`discriminators," '707 application at ,i 66, as opposed to the limitations associated with using
`
`prerecorded events. Second, inference analysis based on previously extracted attributes "greatly
`
`improves the analysis speed of the computer system" as the system can process the attributes
`only instead ofreprocessing the video. See id. at ,i 67. Third, inventing a system for analyzing
`
`"small-sized video primitives abstracted from the video" has many corresponding size-based
`benefits. Id. at ,r 148. 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. See id. All of these benefits flow from the claimed methods, devices, and
`
`computer-readable storage media that make the extraction of attributes independent from the
`
`events that the operator tasks the system to identify.
`
`II.
`
`Procedural Background
`
`On February 29, 2012, a request for inter partes reexamination of the '912 patent was
`
`filed by Bosch Security Systems, Inc., a subsidiary of Robert Bosch GMBH ("Bosch"). On April
`
`10, 2012, the Office granted the request. On December 3, 2012, Patent Owner filed a Petition to
`
`Terminate Reexamination Proceeding Under 35 U .S.C. § 317(b) and 3 7 CFR §§ 1.182,
`
`l .907(b ). The Petition included a Stipulation and Order of Dismissal from a related district court
`
`patent infringement action in which Bosch stipulated and requested that the Court order that
`
`Bosch has not sustained its burden of proving the invalidity of any of the claims 1-22 of the '912
`
`patent. On February 13, 2013, the Office issued a Decision granting the Petition and terminating
`
`the inter partes reexamination of the '912 patent.
`
`On May 24, 2013, an anonymous requester (the "Requester") submitted a Request for Ex
`
`Parte Reexamination ("the Request") of claims 1-22 of the '912 patent. On June 20, 2013, the
`
`Office issued an Order ("the Order") granting the Request. On August 30, 2013, the Office
`
`issued an Office Action ("the Office Action") rejecting claims 1-22 under 35 U .S.C. § 102(b)
`
`and/or under 35 U.S.C. § I 03(a). Patent Owner respectfully submits that the cited references do
`
`not anticipate and would not have rendered obvious the subject matter of any of the rejected
`
`claims. Accordingly, all rejections are traversed, and reconsideration is respectfully requested.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 15
`
`III.
`
`Patent Owner's Statement of the Interview
`
`Patent Owner, Object Video, Inc. representatives Gary Myers and Mitchell Herbert,
`
`technical expert Ken Zeger, and Patent Owner's representatives, Nancy Linck, Martin Zoltick,
`
`and Michael Battaglia, wish to thank Examiners Basehoar and Bonshock and Supervisory Patent
`
`Examiner Kosowski for extending the courtesy of the interview held on October 9, 2013, and for
`
`the helpful and courteous discussions. Patent Owner and Patent Owner's representatives believe
`
`that reexamination of the '912 patent was materially advanced based on the discussion of the
`
`pending claims, the cited references, and the pending rejections. An Agenda for the Interview
`
`and accompanying slide presentation were filed with the Office on October 7, 2013. The Agenda
`
`items were discussed and the slides were presented, including animations comparing an example
`
`of the claimed invention to the system disclosed in the Day reference. The following reasons
`
`. warranting withdrawal of the rejections were addressed during the interview:
`
`• Courtney does not disclose and would not have suggested determining an event that is
`not one of the determined attributes and determining the attributes independent of the
`event.
`
`• Courtney does not disclose and would not have suggested a first processor that
`determines attributes of objects and a separate second processor that determines a first
`event that is not one of the determined attributes.
`
`• Olson does not disclose and would not have suggested determining an event that is not
`one of the determined attributes and determining the attributes independent of the event.
`
`• Olson does not disclose and would not have suggested a first processor that determines
`attributes of objects and a separate second processor that determines a first event that is
`not one of the determined attributes.
`
`• Brill does not disclose and would not have suggested determining an event that is not
`one of the determined attributes and determining the attributes independent of the event.
`
`• Brill does not disclose and would not have suggested a first processor that determines
`attributes of objects and a separate second processor that determines a first event that is
`not one of the determined attributes.
`
`• U.S. Patent Application Serial No. 09/987,707 ("the '707 application"), filed on
`November 15, 2001, discloses a first processor that determines attributes of objects and a
`separate second processor that determines a first event that is not one of the determined
`attributes.
`
`• Claims 6-22 do not require two processors.
`
`• The '707 application discloses the independence-based elements of claims 1-4 and 6-22.
`
`These reasons are explored in depth below.
`
`

`

`Attorney Docket No. 4079-117
`Control No. 90/012,878
`Page 16
`
`Also, during the Interview, the examiners identified the following areas of concern in
`
`connection with the currently pending claims, the cited art, and the Patent Owner's arguments for
`
`patentability, and invited the Patent Owner to respond in its response:
`
`• Broadest reasonable interpretation of the claim terms:
`
`o
`
`"attribute" (Reply, § V.A. & Zeger Dec., 11 24 & 26-30)
`
`o "event" (Reply, § V.A. & Zeger Dec., 11 25-30)
`
`o Attributes independent from identified event claim elements and independence
`requirement (Reply,§ V.B. & Zeger Dec., 1131-35)
`
`•
`
`•
`
`"identifying an event of the object that is not one of the detected attributes
`of the object"
`
`"wherein the plurality of attributes that are detected are independent of
`which event is identified"
`
`• Support for first and second processors and disclosure of transferring video primitives to
`another computer (Reply, § VII.A.I.a. & Zeger Dec., 11 46-50)
`• Support for independence based claim elements (Reply, § VII.A.l.c. & Zeger Dec.,
`1154-58)
`
`• Explanation of the claimed independence and differences between the claimed
`independence and disclosures in Courtney, Olson, and Brill (Reply, §§ V.A., V.B.,
`VII.B.2., VII.C.l., VIII.C.l. & Zeger Dec., 1126-35, 68-82, 88-93, 100-110)
`
`• Courtney and the disclosure of the query Y and meaning of events (Reply, § VII.B.2. &
`Zeger Dec., 11 68-82)
`• Olson and the disclosure of information sent from cameras (Reply, § VII.C.l. & Zeger
`Dec., 11 88-93)
`Each of these concerns is addressed in Patent Owner's response and the accompanying
`
`declaration of Dr. Zeger, as indicated in the highlighted parenthetical after each area of
`
`concern. The examiners are invited to please contact the undersigned representatives of the
`
`Patent Owner with any questions or if there are any other areas of concern that should be
`
`addressed.
`
`IV.
`
`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

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