`EXHIBIT 1015
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 1 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 1 of 10
`
`
`
`Customer No. 035884
`
`Attorney Docket No. 2080-3507
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re application of:
`Jong Wook Lee
`
`Serial No:
`
`11/401,798
`
`Filed:
`
`April 10, 2006
`
`FOR: AUDIO AND VIDEO SYNCHRONIZING
`APPARATUS AND METHOD
`
`Art Unit:
`
`2622
`
`Examiner: DESIR, Jean Wicel
`
`Conf. No.:
`
`6246
`
`RESPONSE TO OFFICE ACTION
`
`Mail Stop Amendment
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Dear Sir:
`
`This paper is in response to the Office Action dated January 6, 2010, in
`
`connection with the above-identified application, the response to which is due April 6,
`
`2010.
`
`It is believed that no fee is due in connection with this paper. Please charge any
`
`fees and credit any overpayment to our deposit account No. 502290. Please enter and
`
`considerthe following amendments and remarks:
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 2 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 2 of 10
`
`
`
`IN THE DRAWINGS:
`
`A substitute drawing sheet is enclosed for FIG. 3 to replace the drawing sheet
`
`submitted in the previous response on October 13, 2009 to the Office Action issued
`
`September3, 2009, that drawing sheet inadvertently adding the label “Related Art” to
`
`FIG. 3. No new matter has been added. Specifically, the following amendments have
`
`been made:
`
`“Related Art” has been deleted from FIG. 3.
`
`2
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 3 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 3 of 10
`
`
`
`IN THE CLAIMS:
`
`No claims are amend. The pending claims are as follows:
`
`1.
`
`(Original) An audio and video synchronizing apparatus comprising:
`
`a video signal processing unit processing a video signal outputted to a display
`
`device of a video processing equipment;
`
`an audio signal processing unit outputting an audio signal, the audio signal
`
`outputted to an audio device of the video processing equipment and synchronized with
`
`the video signal;
`
`a switching unit selecting paths for video signal and audio signal respectively
`
`inputted to the video signal processor and the audio signal processor, and paths for
`
`video and/or audio signals outputted to an external device;
`
`an outputting unit outputting the audio and/or video signal selected by the switch;
`
`and
`
`an output selecting unit controlling the switching unit according to a kind of the
`
`external device connected to the outputting unit, and thus selectively outputting the
`
`audio and/or video signal to the external device.
`
`2.
`
`(Original) The apparatus according to claim 1, further comprising a
`
`detector detecting a kind of the external device connected to the outputting unit.
`
`3.
`
`(Previously presented) The apparatus according to claim 1, wherein the
`
`kind of the external device connectedto the outputting unit is detected to determine
`
`whether the external device is an audio/video device or an audio device.
`
`4.
`
`(Original) The apparatus according to claim 1, wherein whenit is
`
`determined that the external device connected to the outputting unit is an audio device,
`
`the switching unit selects an audio signal synchronized with a video signal outputted to
`
`the display device of the video processing equipment.
`
`3
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 4 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 4 of 10
`
`
`
`5.
`
`(Previously presented) The apparatus according to claim 1, wherein the
`
`kind of the external device connected to the outputting unit is determined according to
`
`whetheror not the external device is connected to a video output port and/or an audio
`
`output port.
`
`6.
`
`(Original) An audio and video synchronizing apparatus comprising:
`
`a video signal processing unit processing a video signal outputted to a display
`
`device of a video processing equipment;
`
`an audio signal processing unit outputting an audio signal, the audio signal
`
`outputted to an audio device of the video processing equipment and synchronized with
`
`the video signal; and
`
`an output selecting unit selecting an audio signal synchronized with the video
`
`signal and outputting the audio signal to an external device.
`
`7.
`
`(Original) An audio and video synchronizing apparatus comprising:
`
`a video signal processing unit processing a video signal outputted to a display
`
`device of a video processing equipment;
`
`an audio signal processing unit outputting an audio signal synchronized with the
`
`video signal; and
`
`an audio output selecting unit selecting an audio signal synchronized with the
`
`video signal, and outputting the audio signal to an external device.
`
`8.
`
`(Original) An audio and video synchronizing apparatus comprising:
`
`a video signal processing unit processing a video signal outputted to a display
`
`device of a video processing equipment;
`
`an audio signal processor outputting an audio signal, the audio signal outputted
`
`to an audio device of the video processing equipment and synchronized with the video
`
`signal;
`
`and
`
`an outputting unit outputting the audio and/or video signal to an external device;
`
`an output selecting unit selectively outputting the audio and/or video signal to the
`
`4
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 5 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 5 of 10
`
`
`
`external device according to a kind of the external device connected to the outputting
`
`unit.
`
`9.
`
`(Original) An audio and video synchronizing apparatus comprising:
`
`a video signal processing unit processing a video signal outputted to a display
`
`device of a video processing equipment;
`
`an audio signal processing unit outputting an audio signal, the audio signal
`
`outputted to an audio device of the video processing equipment and synchronized with
`
`the video signal;
`
`an outputting unit outputting the audio and/or video signal to an external device;
`
`a detecting unit detecting a kind of the external device connected to the
`
`outputting unit; and
`
`an output selecting unit selecting an audio signal synchronized with the video
`
`signal when it is detected that the external device is an audio device, and transmitting
`
`the audio signal to the external audio device through the outputting unit.
`
`10.
`
`(Original) A method of controlling audio and video output comprising:
`
`determining a kind of an external device connected to an output port of a video
`
`processing equipment; and
`
`selecting an audio signal synchronized with a video signal outputted to a display
`
`device of the video processing equipment according to a result of the determination,
`
`and outputting the audio signal to the external device.
`
`11.
`
`(Original) The method according to claim 10, wherein the operation of
`
`determining the kind of the external device determined whetheror not the external
`
`device connected to the output port is an audio device.
`
`12. (Original) The method according to claim 10, further comprising selecting an
`
`audio signal outputted to a speaker of the video processing equipment and
`
`synchronized with the video signal, and outputting the audio signal to the external
`
`device.
`
`5
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 6 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 6 of 10
`
`
`
`13.
`
`(Original) The method according to claim 10, wherein the operation of
`
`selecting the audio signal synchronized with the video signal and outputting the audio
`
`signal to the external device is performed automatically according to a result of the
`
`determination of the kind of the external device.
`
`14.|(Original) The method according to claim 10, wherein the operation of
`
`selecting the audio signal synchronized with the video signal and outputting the audio
`
`signal to the external device is performed by user’s output mode setting.
`
`15. (Original) The method according to claim 10, wherein the audio signal
`
`synchronized with the video signal is an audio signal delayed corresponding to a video
`
`signal processing path.
`
`16. (Original) A methodof controlling audio and video output comprising:
`
`selecting an external device output mode of a video processing equipment; and
`
`selecting an audio signal synchronized with a video signal outputted to a display
`
`device of the video processing equipment whenthe selected output mode is for an
`
`external audio device, and outputting the audio signal to the external audio device.
`
`17.
`
`(Original) The method according to claim 16, further comprising selecting
`
`an audio signal outputted to a speaker of the video processing equipment and
`
`synchronized with the video signal, and outputting the audio signal to the external
`
`device.
`
`18.
`
`(Original) The method according to claim 16, wherein the audio signal
`
`synchronized with the video signal is an audio signal delayed corresponding to a video
`
`signal processing path.
`
`6
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 7 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 7 of 10
`
`
`
`REMARKS
`
`Applicant has studied the Office Action dated January 6, 2010. Claims 1-18 are
`
`pending. No claims have been amended. Claims 1, 6-10 and 16 are independent
`
`claims.
`
`It is submitted that the application is in condition for allowance. Reconsideration
`
`and reexamination are respectfully requested.
`
`Amendments to Drawings
`
`With this paper, amended Figure 3 has been submitted that has the label
`
`“Related Art” removed.
`
`It is respectfully submitted that he previous response submitted
`
`on October 13, 2009 to the Office Action issued September 3, 2009 inadvertently added
`
`the label “Related Art” to FIG. 3.
`
`It is noted that the application as originally filed indicated at paragraph 0026 that
`
`“Fig. 3 illustrates the configuration of an audio and video signal processing unit 40 of a
`
`digital TV, a video processing equipment employing the present invention.” It is further
`
`noted that the only references to “FIG. 3” in the application as originally filed are in the
`
`section labeled “SETIAILED DESCRIPTION OF THE INVENTION”andthat the only
`
`figures referred to in the section labeled “Description of the Related Art” Are FIGS. 1
`
`and 2. Thereforeit is respectfully asserted that “FIG. 3” is not “Related Art” or “Prior
`
`Art.”
`
`§ 102 Rejections
`
`Claims 6 and 7 were rejected under 35 U.S.C. § 102(a) as being anticipated by
`
`the Applicant Admitted Prior Art (AAPA). Applicant respectfully traverses the rejection.
`
`It is noted that the Examiner, at page 2 of the Office Action, baseshis entire
`
`rejection of independentclaims 6 and 7 on the disclosure in “FIG. 3” of the AAPA. It is
`
`further noted that “FIG. 3” of the AAPA wasinadvertently labeled as “Related Art” but
`
`has been re-labeled as not being “Related Art” with this paper. Therefore, it is
`
`respectfully submitted that “FIG. 3” is not part of the AAPA and, therefore, the Examiner
`
`has actually based his rejection on the actual disclosure of the present invention to
`
`7
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 8 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 8 of 10
`
`
`
`which independentclaims 6 and 7 are properly directed and it is respectfully requested
`
`that the rejection be withdrawn.
`
`§ 103 Rejections
`
`Claims 1-5 and 8-18 were rejected under 35 U.S.C. § 103(a) as being
`
`unpatentable over the AAPAin view of Maeharaetal. (“Maehara” U.S. Pub. No.
`
`2005/0147129). This rejection is respectfully traversed.
`
`It is noted that the Federal Circuit has provided that an Examiner must establish
`
`a caseof prima facie obviousness. Otherwise the rejection is incorrect and must be
`
`overturned. As the court recently stated in In re Rijkaert, 28 USPQ2d 1955, 1956 (Fed.
`
`Cir. 1993):
`
`“In rejecting claims under 35 U.S.C. § 103, the examiner bears the initial burden
`
`of presenting a prima facie case of obviousness. Onlyif that burden is met, does the
`
`burden of coming forward with evidence or argumentshift to the applicant.
`
`‘A prima
`
`facie case of obviousnessis established when the teachings from the prior art itself
`
`would appear to have suggested the claimed subject matter to a person ofordinary skill
`
`in the art.’
`
`If the examiner fails to establish a prima facie case, the rejection is improper
`
`andwill be overturned.” (citations omitted.)
`
`It is noted that the Examiner, at pages 3-5 of the Office Action, bases his
`
`rejections of independentclaims 1, 8-10 and 16 primarily on “FIG. 3” of the AAPA, with
`
`Maehara asserted only with respect to the recitation of “according to a kind of the
`
`external device.” As previously respectfully submitted, “FIG. 3” is not “Related Art” or
`
`part of the AAPA. It is further respectfully submitted that Maehara fails to disclose the
`
`limitations that “FIG. 3” has been cited as disclosing.
`
`Therefore, it is respectfully asserted that independent claims 1, 8-10 and 16 are
`
`allowable over the asserted combination of references.
`
`It is further respectfully asserted
`
`that claims 2-5, 11-15, 17 and 18 also are allowable over the cited combination of
`
`referencesat least by virtue of their dependence from an allowable independent claim.
`
`8
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 9 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 9 of 10
`
`
`
`CONCLUSION
`
`In view of the above remarks, Applicant submits that claims 1-18 of the present
`
`application are in condition for allowance. Reexamination and reconsideration of the
`
`application, as originally filed, are requested.
`
`If for any reason the Examinerfinds the application other than in condition for
`
`allowance, the Examiner is requested to call the undersigned attorney at the Los
`
`Angeles, California telephone number(213) 623-2221 to discuss the steps necessary
`
`for placing the application in condition for allowance.
`
`LEE, HONG, DEGERMAN, KANG & WAIMEY
`
`
`
`Date: April 5, 2010 By:__/Richard C. Salfelder/
`Richard C. Salfelder
`Registration No. 51,127
`Attorney for Applicant(s)
`
`Customer No. 035884
`
`Enclosure: Substitute FIG. 3
`
`9
`
`Attorney Docket No. 2080-3507
`
`Ex. 1015 — TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE — IPR2023-00240
`Page 10 of 10
`
`Ex. 1015 – TCL Indus Holdings Co., Ltd.
`TCL Indus Holdings Co., Ltd. v. LGE – IPR2023-00240
`Page 10 of 10
`
`