Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 1 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 1 of 19
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`EXHIBIT 11
`EXHIBIT 11
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`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 2 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 2 of 19
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`Attorney Docket No, ALPH.P020
`
`IN THE UNITED STATES PATENT OFFICE
`
`PATENT
`
`Examiner: Devona E. Faulk
`Art Unit:
`2614
`
`) ) ) ) ) ) ) ) ) )
`
`In Re Patent Application of:
`
`Gregory C. Burnett, et al.
`
`Application No.: 10/400,282
`
`Filed: March 27, 2003
`
`For:|MICROPHONE AND VOICE ACTIVITY
`DETECTION (VAD) CONFIGURATIONS FOR
`USE WITH COMMUNICATION SYSTEMS
`
`)
`
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`RESPONSE TO OFFICE ACTION
`
`Sir:
`
`This is a response to the Office Action mailed August 17, 2010. Applicant
`
`respectfully requests entry ofthe following Amendments and consideration of the
`
`Remarks.
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`

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`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 3 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 3 of 19
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`Attorney Docket No. ALPH.P020
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`IN THE CLAIMS
`
`AMENDMENTS
`
`1
`
`(Currently amended) A communications system, comprising:
`
`a voice detection subsystem receiving voice activity signals that include
`
`information of human voicing activity and automatically generating control signals
`
`using information of the voice activity signals; and
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`a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearrayincluding a plurality of microphones,
`
`whereinafirst microphoneofthearrayis fixed at a first position relative to a mouth of
`
`a user, wherein the first position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthearray is fixed at a secondposition relative
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`to the mouth, wherein the secondpositionorients a front of the second microphone
`
`away from the mouth such that the second position forms an angle relative to thefirst
`
`position, wherein the angle is greater than zero degrees, the microphonearray
`
`providing acoustic signals of an environment to components ofthe denoising
`
`subsystem, components of the denoising subsystem automatically selecting at least one
`
`denoising method appropriate to data of at least one frequency subband ofthe acoustic
`
`signals using the control signals and processing the acoustic signals using the selected
`
`denoising method to generate denoised acoustic signals, wherein the denoising method
`
`includes generating a noise waveform estimate associated with noise of the acoustic
`
`signals and subtracting the noise waveform estimate from the acoustic signal when the
`
`acoustic signal includes speech and noise.
`
`Claims 2 and 3 (Canceled).
`
`4.
`
`(Previously presented)
`
`The system of claim 1, wherein the voice
`
`detection subsystem further comprises:
`
`at least one glottal electromagnetic micropower sensor (GEMS)including at
`
`least one antenna for receiving the voice activity signals; and
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 4 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 4 of 19
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`Attorney Docket No. ALPH.P020
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`at least one voice activity detector (VAD) algorithm for processing the GEMS
`voice activity signals and generating the control signals.
`
`x,
`
`(Previously presented)
`
`The system of claim 1, wherein the voice
`
`detection subsystem further comprises:
`
`at least one accelerometer sensorin contact with skin of a user for receiving the
`
`voice activity signals; and
`
`at least one voice activity detector (VAD) algorithm for processing the
`
`accelerometer sensor voice activity signals and generating the control signals.
`
`6.
`
`(Previously presented)
`
`The system of claim 1, wherein the voice
`
`detection subsystem further comprises:
`
`at least one skin-surface microphonesensorin contact with skin of a user for
`
`receiving the voice activity signals; and
`
`at least one voice activity detector (VAD) algorithm for processing the skin-
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`surface microphonesensorvoice activity signals and generating the controlsignals.
`
`a
`
`(Previously presented)
`
`The system of claim 1, wherein the voice
`
`detection subsystem receives voice activity signals via couplings with the microphones.
`
`Claim 8 (Canceled).
`
`9.
`
`(Previously presented)
`
`The system of claim 1, wherein the voice
`
`detection subsystem further comprises at least one manually activated voice activity
`
`detector (VAD) for generating the voice activity signals.
`
`10.
`
`(Previously presented)
`
`The system of claim 1, further including a
`
`portable handset that includes the microphones, wherein the portable handset includes
`
`at least one of cellular telephones, satellite telephones, portable telephones, wireline
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 5 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 5 of 19
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`Attorney Docket No. ALPH.P020
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`telephones, Internet telephones, wireless transceivers, wireless communication radios,
`
`personal digital assistants (PDAs), and personal computers (PCs).
`
`1l.
`
`(Previously presented)
`
`The system of claim 10, wherein the portable
`
`handset includesat least one of the voice detection subsystem and the denoising
`
`subsystem.
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`12.
`
`(Previously presented)
`
`The system of claim 1, further including a
`
`portable headset that includes the microphonesalong with at least one speaker device.
`
`13,
`
`(Previously presented)
`
`The system of claim 12, wherein the portable
`
`headset couplesto at least one communication device selected from among cellular
`
`telephones, satellite telephones, portable telephones, wireline telephones, Internet
`
`telephones, wireless transceivers, wireless communication radios, personal digital
`
`assistants (PDAs), and personal computers (PCs),
`
`
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`14.—_(Previously presented) The system of claim 13, wherein the portable
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`headset couples to the communication device using at least one of wireless couplings,
`
`wired couplings, and combination wireless and wired couplings.
`
`15.
`
`(Previously presented)
`
`The system of claim 13, wherein the
`
`communication device includesat least one of the voice detection subsystem and the
`
`denoising subsystem.
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`16.
`
`(Previously presented)
`
`The system of claim 12, wherein the portable
`
`headset includesat least one of the voice detection subsystem and the denoising
`
`subsystem.
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`17.
`
`(Previously presented)
`
`The system of claim 12, wherein the portable
`
`headset is a portable communication device selected from amongcellular telephones,
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 6 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 6 of 19
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`Attorney Docket No. ALPH.P020
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`satellite telephones, portable telephones, wireline telephones, Internet telephones,
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`wireless transceivers, wireless communication radios, personaldigital assistants
`
`(PDAs), and personal computers (PCs).
`
`Claims 18-40 (Canceled).
`
`41.
`
`(Currently amended) A communications system, comprising:
`
`a voice detection subsystem receiving voice activity signals that include
`
`information of human voicing activity and automatically generating control signals
`
`using information of the voice activity signals;
`
`a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray includinga plurality of microphones,
`
`wherein a first microphoneofthe arrayis fixed ata first position relative to a mouth of
`
`a user, wherein the first position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe array is fixed at a second position relative
`
`to the mouth, wherein the secondposition orients a front of the second microphone
`
`away from the mouth such that the second position forms an angle relative to thefirst
`
`position, wherein the angle is greater than zero degrees, the microphone array
`
`providing acoustic signals of an environment to components of the denoising
`
`subsystem, components ofthe denoising subsystem automatically selecting at least one
`
`denoising method appropriate to data of at least one frequency subband ofthe acoustic
`
`signals using the control signals and processing the acoustic signals using the selected
`
`denoising method to generate denoised acoustic signals, wherein the denoising method
`
`includes generating a noise waveform estimate associated with noise of the acoustic
`
`signals and subtracting the noise waveform estimate from the acoustic signal when the
`
`acoustic signal includes speech and noise; and
`
`a portable headset comprising the microphonesandat least one speaker device,
`
`wherein the portable headset couples to at least one communication device selected
`
`from amongcellular telephones,satellite telephones, portable telephones, wireline
`telephones, Internet telephones, wireless transceivers, wireless communication radios,
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 7 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 7 of 19
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`Attorney Docket No. ALPH.P020
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`personal digital assistants (PDAs), personal computers (PCs), and at least one ofthe
`
`voice detection subsystem and the denoising subsystem.
`
`Claims 42-43 (Canceled).
`
`
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`44.—_(Previously presented) The system of claim 1, whereinthefirst
`
`microphoneis a unidirectional microphone and the second microphoneis a
`
`unidirectional microphone.
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`45.
`
`(Previously presented)
`
`The system ofclaim 44, wherein thefirst
`
`microphoneand the second microphoneare separated by a distance in a range of
`
`approximately zero (0) centimeters to 15 centimeters.
`
`46.
`
`(Currently amended) The system ofclaim 44, wherein the angle is in a range
`
`of approximately greater than zero (0) degrees te and one of equal to and less than 180
`
`degrees.
`
`47.
`
`(Currently amended) The system of claim 44, wherein the angle is in a range
`
`of approximately greater than zero (0) degrees te and one of equal to and less than 135
`
`degrees.
`
`48.
`
`(Currently amended) The system of claim 44, wherein the angle is in a range
`
`of approximately greater than zero (0) degrees te and one of equal to and greater than
`
`90 degrees.
`
`
`
`49.—_(Previously presented) The system of claim 1, wherein thefirst
`
`microphoneis an omnidirectional microphone and the second microphoneis a
`
`unidirectional microphone.
`
`

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`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 8 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 8 of 19
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`Attorney Docket No. ALPH.P020
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`50.
`
`(Previously presented)
`
`The system of claim 49, wherein the first
`
`microphone and the second microphoneare separated by a distance approximately in a
`
`range of zero (0) centimeters to 15 centimeters.
`
`51.
`
`(Previously presented)
`
`The system of claim 49, wherein the angle is
`
`approximately in a range of 30 degrees to 180 degrees.
`
`52.
`
`(Previously presented)
`
`The system of claim 49, wherein the angle is
`
`approximatelyin a range of 60 degrees to 180 degrees.
`
`53.
`
`(Previously presented)
`
`The system of claim 49, wherein the angle is
`
`approximately in a range of 90 degrees to 180 degrees.
`
`54.
`
`(Previously presented)
`
`The system of claim 1, wherein thefirst
`
`microphoneis a unidirectional microphone and the second microphoneis an
`
`omnidirectional microphone.
`
`55.
`
`(Previously presented)
`
`The system of claim 54, wherein thefirst
`
`microphone and the second microphoneare separated by a distance approximately in a
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`range ofzero (0) centimeters to 15 centimeters.
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 9 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 9 of 19
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`Attorney Docket No. ALPH.P020
`
`REMARKS
`
`Claims 1, 4-7, 9-17, 41, and 44-55 are pendingin the application. Claims 1, 4-
`
`7, 9-17, 41, and 44-55 are rejected. Claims 1, 41, and 46-48 are amended herein. No
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`new material is added by the amendmentsherein.
`
`Request for Continued Examination under 37 C.F.R. 1.114
`
`This response is accompanied by a Request for Continued Examination under
`
`37 C.F.R. 1.114 and the required fee.
`
`Petition for extension of time
`
`A petition for a three (3) month extension of time under 37 C.F.R. §1.136(a) is
`
`included herewith, as well as the fee under 37 C.F.R. §1.117(a)(3).
`
`Rejections under 35 U.S.C. § 102
`
`Claims1 and 7 are rejected under 35 U.S.C. § 102(b) as being unpatentable
`
`over Yoshidaet al., United States (US) Patent Number 5,473,702 (“Yoshida”).
`
`Applicant respectfully submits that the claims as presented herein are patentably
`
`distinct from Yoshida. Moreover, and as supported below, Yoshidafails to teach each
`
`and every element of claims | and 7 as presented herein.
`
`Regarding claim 1, as amended, Applicant submits that Yoshida does not
`
`disclose a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray includinga plurality of microphones,
`
`whereinafirst microphoneofthe array is fixed at a first position relative to a mouth of
`
`a user, wherein the first position orients a front ofthe first microphone towards the
`
`mouth, wherein a second microphoneofthe array is fixed ata second position relative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth such that the second position forms an angle relative to the first
`
`position, wherein the angle is greater than zero degrees (emphasis added).
`
`Applicant submits that Yoshida shows two microphones 1 and 2 (Figures | and
`
`2). Yoshida discloses that microphone1 is disposed relatively close to a voice source
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 10 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 10 of 19
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`Attorney Docket No. ALPH.P020
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`and picks up both voice input and backgroundnoise (column 3, lines 10-13). Yoshida
`
`discloses that microphone 2 is disposedrelatively far from the voice source and picks
`
`up mainly noise (column3, lines 16-18). However, Yoshida includes no further
`
`description regarding the relative positioning of the two microphones. Therefore,
`
`while Yoshida shows a system having two microphones, Yoshida does not show or
`
`describe a first microphoneofan array fixed at a first position relative to a mouth of a
`
`user, wherein the first position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe array is fixed at a second positionrelative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth such that the second position forms an anglerelative to the first
`
`position, wherein the angle is greater than zero degrees (emphasis added).
`
`The Office Action states at page 2 that Yoshida reads on the “suchthat the
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`second position formsan anglerelative to the first position” language, and that
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`“implicitly some angle is formed relative to the first position.” Applicant disagrees
`
`with this statement. Applicant submits that Yoshida does describe a configuration in
`
`whicha first microphoneis disposedrelatively close to a voice source and a second
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`microphoneis disposed relatively far from the voice source (emphasis added).
`
`However, a physical relationship between a voice source and each of two microphones
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`described in Yoshidais different than a physical relationship between the front of two
`
`microphonesas claimed in claim 1. More specifically, Applicant submits that, while
`
`the physical relationship between a voice source and each of two microphones
`
`described in Yoshida may imply generic information about a difference in angles
`
`between the voice source and each of two microphones, the physical relationship
`
`between each microphoneand a voice source does not describe or even imply any
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`information about the physical relationship between the front of the two microphones
`
`(emphasis added).
`
`Furthermore, Applicant reminds the examinerthatall limitations of the claim
`
`are to be considered. To that point, Yoshida does not describe a microphonearray in
`
`
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`whichafirstmicrophoneofthearrayisfixedatafirstpositionrelativetoamouthofa
`
`
`
`
`
`
`
`
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`user, wherein thefirstorientsafrontofthefirstmicrophonetowardstheposition
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`
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`

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`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 11 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 11 of 19
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`Attorney Docket No. ALPH.P020
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`mouth (emphasis added). Additionally, Yoshida does not describe a microphonearray
`
`in which a second microphoneofthe array is fixed at a second position relative to the
`
`mouth, wherein the second position orients a front of the second microphone away
`
`from the mouth (emphasis added). Furthermore, Yoshida does not describe a
`
`relationship between a first microphone and a second microphone in which a second
`
`position of a second microphone formsan anglerelative to a first position of a first
`
`microphone, wherein the angle is greater than zero degrees (emphasis added).
`
`For at least these reasons, Applicant respectfully submits that amendedclaim 1
`
`is not anticipated by Yoshida.
`
`Asclaim 7 depends from amended claim 1 and includes further limitations
`
`thereon, and since amended claim 1 is not anticipated by Yoshida, Applicant submits
`
`that claim 7 is not anticipated by Yoshida.
`
`Rejections under 35 U.S.C.§103
`
`Claims 49-55 are rejected under 35 U.S.C. § 103(a) as being unpatentable over
`
`Yoshida et al., United States (US) Patent Number 5,473,702 (“Yoshida”) in view of
`
`Ouyanget al., US Patent Application Publication number US 2003/0044025
`
`(“Ouyang”). Applicant respectfully traverses the rejection.
`
`Regarding claim 1, as amended, Applicant submits that Yoshida does not
`disclose a denoising subsystem coupled to the voice detection subsystem, the denoising
`subsystem comprising a microphonearray includinga plurality of microphones,
`
`wherein a first microphoneofthe array is fixedat a first position relative to a mouth of
`
`a user, wherein thefirst position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe arrayis fixed at a second position relative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth such that the second position forms an angle relativeto the first
`
`
`
`
`
`position, wherein theangleisgreaterthanzerodegrees(emphasis added).
`
`Applicant submits that Yoshida shows two microphones | and 2 (Figures 1 and
`
`2). Yoshida discloses that microphone | is disposed relatively close to a voice source
`
`and picks up both voice input and background noise (column3, lines 10-13). Yoshida
`
`10
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 12 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 12 of 19
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`Attorney Docket No. ALPH.P020
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`discloses that microphone2 is disposed relatively far from the voice source and picks
`up mainly noise (column3, lines 16-18). However, Yoshida includes no further
`
`description regarding the relative positioning of the two microphones. Therefore,
`
`while Yoshida shows a system having two microphones, Yoshida does not show or
`
`describe a microphonearray in whicha first microphone ofthe arrayis fixed at a first
`
`position relative to a mouth of a user, whereinthefirst position orients a front ofthe
`
`first microphone towards the mouth (emphasis added). Additionally, Yoshida does not
`
`describe a microphonearray in which a second microphoneofthe arrayis fixed at a
`
`second position relative to the mouth, wherein the second position orients a front ofthe
`
`second microphone away from the mouth (emphasis added). Furthermore, Yoshida
`
`does not describe a relationship between a first microphone and a second microphone
`
`in which a second position of a second microphone formsan anglerelativeto a first
`
`position ofa first microphone, wherein the angle is greater than zero degrees (emphasis
`
`added).
`
`The Office Action states at page 4 that, regarding claims 49 and 54, Yoshida
`
`does not disclose one omnidirectional microphone and one unidirectional microphone,
`
`the microphones separated by a distance. Applicant agrees with this statement. The
`
`Office Action states howeverthat it would have been obvious to modify Yoshida by
`
`substituting the microphone configuration of Ouyang. Applicant disagrees with this
`
`assertion.
`
`Applicant submits Ouyang teaches a microphonecircuit that includes a uni-
`
`directional microphone, an omni-directional microphone, and a background noise
`
`suppression circuit (paragraph 0034). The omni-directional microphoneis located in
`
`close physical proximity to the uni-directional microphonesuch that an acoustic source
`
`is approximately equal distance from both the omni-directional microphone and the
`
`uni-directional microphone (paragraph 0037). Ouyang teaches a single embodiment of
`
`the microphonecircuit as a desk top speaker phone that embodies the microphone
`
`circuit (paragraph 0047). In the desk top speaker phone, the uni-directional
`
`microphoneand the omni-directional microphoneare positioned in a front-facing
`
`region of a housing in close proximity to each other such that an acoustic source spaced
`
`1]
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 13 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 13 of 19
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`Attorney Docket No. ALPH.P020
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`apart from the speaker phone is approximately the same distance from each of the
`omni-directional microphoneandthe uni-directional microphone (paragraph 48; figure
`8),
`
`The embodimenttaught in Ouyang therefore describes two microphones
`
`positioned in a face of a housing surface such that the two microphonesfacein the
`
`samedirection outward from the housing surface and, as such, position the
`
`microphonessuchthat an acoustic source is approximately equal distance from a face
`
`of both microphones, Consequently, Ouyang does not show or describe a microphone
`
`array in whichafirst microphoneof the arrayis fixed at a first position relative to a
`
`mouth ofa user, wherein the first position orients a front of the first microphone
`
`towards the mouth (emphasis added). Additionally, Ouyang does not describe a
`
`microphone array in which a second microphoneofthe array is fixed at a second
`
`position relative to the mouth, wherein the second position orients a front of the second
`
`microphone away from the mouth (emphasis added). Furthermore, Ouyang does not
`
`describe a relationship between a first microphone and a second microphone in which a
`
`second position of a second microphone forms an angle relative to a first position of a
`
`first microphone, wherein the angle is greater than zero degrees (emphasis added).
`
`Therefore, Applicant submits that Ouyang does not disclose a microphone array
`
`including a plurality of microphones, wherein a first microphoneofthe arrayis fixed at
`
`a first position relative to a mouth of a user, wherein the first position orients a front of
`
`the first microphone towards the mouth, wherein a second microphoneofthe array is
`
`fixed at a second position relative to the mouth, wherein the second position orients a
`
`front of the second microphone away from the mouth suchthat the second position
`
`
`
`forms an anglerelative to the first position, wherein the angle is greaterthanzero
`
`degrees (emphasis added). Therefore, Ouyang does not overcomethe deficiencies of
`
`Yoshida with regard to claim 1.
`
`As claims 49-55 depend from amended claim 1 and include further limitations
`
`thereon, and since amendedclaim | is not anticipated by Yoshida in view of Ouyang,
`
`Applicant submits that claims 49-55 are not anticipated by Yoshida in view of Ouyang.
`
`12
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 14 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 14 of 19
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`Attorney Docket No. ALPH.P020
`
`The Office Action states at page 5 that, regarding claims 50 and 55, while
`
`Yoshida in view of Ouyangissilent as to separation distance, separation distanceis a
`
`matter of design choice, Applicant disagrees and officially challenges this assertion,
`
`and further submits that this rejection is improper. Applicant submits that in any signal
`
`collection and processing system all elements of a configuration collectively affect
`
`operation of the system. As neither Yoshida nor Ouyang describe a first microphone
`
`and the second microphoneseparated by a distance approximately in a range of zero
`
`(0) centimeters to 15 centimeters, Applicant requests the examiner provide a reference
`
`that describes this configuration. Therefore, Applicant submits that claims 50 and 55
`
`are patentable over Yoshida in view of Ouyang.
`
`The Office Action states at page 5 that, regarding claims 51-53, while Yoshida
`
`in view of Ouyangissilent as to relative angle between the fronts of two microphones,
`
`relative angle is a matter of design choice. Applicant disagrees and officially
`
`challenges this assertion, and further submits that this rejection is improper. Applicant
`
`submits that in any signal collection and processing system all elements of a
`
`configuration collectively affect operation of the system. As neither Yoshida nor
`
`Ouyang describe any configuration in which an angle is approximately in a range of 30
`
`degrees to 180 degrees, an angle is approximately in a range of 60 degrees to 180
`
`degrees, and an angle is approximatelyin a range of 90 degrees to 180 degrees,
`
`Applicant requests the examiner provide a reference that describes this configuration.
`
`Therefore, Applicant submits that claims 51-53 are patentable over Yoshida in view of
`
`Ouyang.
`
`Claims 4, 6, and 9 are rejected under 35 U.S.C. § 103(a) as being unpatentable
`
`over Yoshida. Applicant respectfully traverses the rejection.
`
`Regarding claim 1, and as described in detail above, Yoshida doesnot disclose
`
`a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray including a plurality of microphones,
`
`wherein a first microphoneofthe array is fixed at a first position relative to a mouth of
`
`a user, wherein thefirst position orients a front ofthe first microphone towards the
`
`13
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 15 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 15 of 19
`
`Attorney Docket No. ALPH.P020
`
`mouth, wherein a second microphoneofthe array is fixed at a second position relative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth such that the second position forms an anglerelative to the first
`
`position, wherein the angle is greater than zero degrees (emphasis added).
`
`Asclaims 4, 6, and 9 depend from amendedclaim 1 and include further
`
`limitations thereon, and since amended claim | is not anticipated by Yoshida,
`
`Applicant submits that claims 4, 6, and 9 are not anticipated by Yoshida.
`
`Claim 5 is rejected under 35 U.S.C. § 103(a) as being unpatentable over
`
`Yoshida in view ofPark et al., US patent number 5,590,241 (hereinafter “Park’’).
`
`Applicant respectfully traverses the rejection.
`
`Regarding amended claim 1, Applicant submits that Yoshida does not disclose
`
`a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray including a plurality of microphones,
`
`wherein a first microphoneofthe arrayis fixed at a first position relative to a mouth of
`
`a user, wherein thefirst position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe arrayis fixed at a second position relative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth suchthat the second position forms an angle relative to the first
`
`position, wherein the angle is greater than zero degrees (emphasis added).
`
`Furthermore, Yoshida and Park, alone or in any combination, do not disclose a
`
`denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray including a plurality of microphones,
`
`wherein a first microphoneofthe array is fixed at a first position relative to a mouth of
`
`a user, wherein the first position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe array is fixed at a second position relative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth such that thesecondpositionformsananglerelativetothefirst
`
`
`
`
`position, wherein the angle is greater than zero degrees (emphasis added).
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 16 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 16 of 19
`
`Attorney Docket No. ALPH.P020
`
`As claim 5 depends from amended claim 1 and includesfurther limitations
`
`thereon, and since amendedclaim 1 is not anticipated by Yoshida and/or Park,
`
`Applicant submits that claim 5 is not anticipated by Yoshida and/or Park.
`
`Claims 10-17 are rejected under 35 U.S.C. § 103(a) as being unpatentable over
`Yoshida in view of Housni, US patent number 6,795,713 (hereinafter “Housni”).
`
`Applicant respectfully traverses the rejection.
`
`Regarding amended claim 1, and as described in detail above, Applicant
`
`submits that Yoshida does not disclose a denoising subsystem coupled to the voice
`
`detection subsystem, the denoising subsystem comprising a microphonearray
`
`including a plurality of microphones, wherein a first microphoneofthe array is fixed at
`
`a first position relative to a mouth of a user, whereinthe first position orients a front of
`
`the first microphone towards the mouth, wherein a second microphoneofthe arrayis
`
`fixed at a second position relative to the mouth, wherein the second position orients a
`
`front of the second microphone awayfrom the mouth suchthat the second position
`
`forms an angle relative to the first position, wherein the angle is greater than zero
`
`degrees (emphasis added).
`
`Furthermore, Yoshida and Housni, alone or in any combination, do not disclose
`
`a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray including a plurality of microphones,
`
`wherein a first microphoneofthe array is fixed at a first position relative to a mouth of
`
`a user, wherein the first position orients a frontof the first microphone towardsthe
`
`mouth, wherein a second microphoneofthe array is fixed at a second position relative
`
`to the mouth, wherein the secondposition orients a front of the second microphone
`
`
`
`
`
`away from the mouth suchthat thesecondpositionformsananglerelativetothefirst
`
`
`
`
`
`position, wherein the angle is greater than zero degrees (emphasis added),
`
`As claims 10-17 depend from amended claim 1 and include further limitations
`
`thereon, and since amendedclaim 1 is not anticipated by Yoshida and/or Housni,
`
`Applicant submits that claims 10-17 are not anticipated by Yoshida and/or Housni.
`
`15
`
`

`

`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 17 of 19
`Case 6:21-cv-00984-ADA Document 55-11 Filed 05/25/22 Page 17 of 19
`
`Attorney Docket No. ALPH.P020
`
`Claim 41 is rejected under 35 U.S.C. § 103(a) as being unpatentable over
`Yoshida in view of Ouyang and further in view of Turnbull et al., US patent number
`
`6,980,092 (hereinafter “Turnbull’”). Applicant respectfully traverses the rejection.
`
`Regarding claim 41, as amendedherein, and as described in detail above with
`
`reference to claim 1, Applicant submits that Yoshida in view of Ouyang does not
`
`disclose a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearrayincluding a plurality of microphones,
`
`wherein a first microphone ofthe array is fixed at a first position relative to a mouth of
`
`a user, wherein thefirst position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe array is fixed at a second positionrelative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouth suchthat the second position forms an angle relative to the first
`
`position, wherein the angleis greater than zero degrees (emphasis added).
`
`Additionally, Turnbull does not disclose a communications system, comprising
`
`a denoising subsystem coupled to the voice detection subsystem, the denoising
`
`subsystem comprising a microphonearray including a plurality of microphones,
`
`wherein a first microphoneofthe arrayis fixed at a first position relative to a mouth of
`
`a user, wherein the first position orients a front of the first microphone towards the
`
`mouth, wherein a second microphoneofthe array is fixed at a second position relative
`
`to the mouth, wherein the second position orients a front of the second microphone
`
`away from the mouthsuch that the second position forms an angle relative to the first
`
`position, wherein th