`Reply dated June 13, 2012
`Response to Office Action of March 16, 2012
`
`REMARKS
`
`New claim 13 has been added. Accordingly, claims 1-13 are currently pending in the
`
`application, of which claims 1, 7 and 13 are independent.
`
`Applicant respectfully submits that the above amendments do not add new matter to the
`
`application and are fully supported by the specification. Support for the added claim may be
`
`found at least in Figures 1-4 and at paragraphs [0023]—[0051] of the specification.
`
`In view of the above Amendments and following Remarks, Applicant respectfully
`
`requests reconsideration and timely withdrawal of the pending rejections for the reasons
`
`discussed below.
`
`Rejections Under 35 U.S.C. § 103
`
`To establish an obviousness rejection under 35 U.S.C. § 103(a), four factual inquiries
`
`must be examined. The four factual inquiries include (a) determining the scope and contents of
`
`the prior art; (b) ascertaining the differences between the prior art and the claims in issue; (0)
`
`resolving the level of ordinary skill in the pertinent art; and (d) evaluating evidence of secondary
`
`consideration. Graham v. John Deere, 383 U.S. 1, 17-18 (1966).
`
`In view of these four factors, the analysis supporting a rejection under 35 U.S.C. 103(a)
`
`should be made explicit, and should “identify a reason that would have prompted a person of
`
`ordinary skill in the relevant field to combine the [prior art] elements" in the manner claimed.
`
`KSR lnt’l. Co. v. Telef/ex, Inc., 127 S. Ct. 1727, 82 USPQZd 1385, 1396 (2007). The Federal
`
`Circuit requires that "rejections on obviousness cannot be sustained with mere conclusory
`
`statements; instead, there must be some articulated reasoning with some rational underpinning
`
`to support the legal conclusion of obviousness." In re Kahn, 441 F.3d 977, 988, 78 USPQ2d
`
`1329, 1336 (Fed. Cir. 2006).
`
`
`
`Application No.: 12/547,849
`Reply dated June 13, 2012
`Response to Office Action of March 16, 2012
`
`Finally, even if the prior art may be combined, there must be a reasonable expectation of
`
`success, and the reference or references, when combined, must disclose or suggest every
`
`claimed feature. See in re Vaeck, 947 F.2d 488, 20 USPQ2d 1438 (Fed. Cir. 1991).
`
`Claims 1-12 stand rejected under 35 U.S.C. § 103(a) as being allegedly unpatentable
`
`over U.S. Patent Publication No. 2007/0206126, applied for by Lin, etal. (“Lin”) in view of U.S.
`
`Patent Publication No. 2004/0075800, applied for by Sah, etal. (“Sah”). Applicant respectfully
`
`traverses this rejection for at least the following reasons.
`
`Claim 1 recites, in relevant part:
`
`a single driving circuit chip disposed on the flexible circuit film;
`a repair line and a repair bar disposed in the peripheral area of the thin film
`transistor array panel;
`a repair amplifier disposed on the driving circuit chip, and connected to the repair
`line and the repair bar;
`a repair input line connecting the repair bar and the repair amplifier; and
`a repair output line connecting the repair amplifier and the repair line (emphasis
`
`added)
`
`In the Office Action, the examiner concedes that Lin fails to disclose each and every
`
`feature of claim 1, but relies on Sah to cure the deficiencies of Lin. Office Action, page 2.
`
`Specifically, the examiner argues that deficiencies of Lin are cured because Sah discloses “an
`
`output amplifier on the repair line path in order to avoid the distortion of the image signal caused
`
`by a long transmitting path”. Office Action, page 2. Applicant respectfully disagrees and notes
`
`that the examiner summarizes the claim language to fit the prior art. Sah discloses “[f]or
`
`avoiding the distortion of the image signal because of the long transmitting path, one can add
`
`output amplifiers on the repair line path of the X-board or the Y-board [(i.e., circuit board)]”.
`
`Sah, paragraph [0033] (emphasis added).
`
`In contrast, claim 1 recites “a single driving circuit
`
`chip disposed on the flexible circuit film...[and] a repair amplifier disposed on the driving circuit
`
`c_hip”. (emphasis added). Since Sah discloses that output amplifiers are disposed on a circuit
`
`
`
`Application No.: 12/547,849
`Reply dated June 13, 2012
`Response to Office Action of March 16, 2012
`
`board (i.e., X-board or the Y-board), even if Lin and Sah may be combined as the examiner
`
`suggests, resultant would dispose the output amplifier of Sah on Lin’s circuit board 207 of FIG. 2
`
`but not “on the driving circuit chip” as recited in claim 1. Further, there is no disclosure in either
`
`reference that would have prompted a person ordinarily skilled in the art (POSITA) to dispose
`
`Sah’s output amplifier on a Lin’s driving circuit chip (i.e., driving chip 205 of FIG. 2), which is
`
`disposed on a flexible circuit film (i.e., Lin’s flexible board 206a of FIG. 2). As such, Sah fails to
`
`cure the deficiencies of Lin.
`
`Secondly, Lin in view of Sah also fails to disclose at least “a si_ngl_e driving chip disposed
`
`on the flexible circuit film”. (emphasis added). Lin discloses at least two driving chips, a source
`
`driving chip 205 of FIG. 2 and a gate driving chip 204 of FIG. 2. Lin, paragraph [0017].
`
`Similarly, Sah discloses two IC chips, one for each of the two Tape Carrier Packages (TCPs)
`
`(i.e., TOP 18 and 20, or TOP 48 and 50). Sah, paragraph [0021], see FIG. 2-3. Accordingly, Lin
`
`and Sah, alone or in combination, fail to disclose each and every feature of claim 1.
`
`Further, the examiner also argues that “[i]t would have been obvious to one of ordinary
`
`skill in the art at the time of invention to add a repair amplifier due to the benefits taught by Sah”.
`
`Office Action, page 2. The examiner makes similar conclusive analysis for claims 2-6 and 8-12.
`
`The Federal Circuit held that the “mere identification in the prior art of each element is
`
`insufficient to defeat the patentability of the combined subject matter as a whole”, but rather an
`
`articulated reasoning must be provided to support the conclusion it would have been obvious to
`
`make the claimed invention.
`
`In re Kahn, 441 F.3d 977, 986 (Fed. Cir. 2006) (emphasis added).
`
`Here, the examiner fails to cite any evidence or support in reaching a conclusion that every
`
`element of the recited claim is disclosed through a combination of prior art or that such
`
`modification involves only routine skill in the art. In addition, Applicant also notes that the
`
`examiner fails to satisfy the requirements of taking Official Notice with respect to claims 5 and
`
`
`
`Application No.: 12/547,849
`Reply dated June 13, 2012
`Response to Office Action of March 16, 2012
`
`12 (which Applicant would traverse if such Office Notice had been taken) for asserted common
`
`knowledge or practice. Accordingly, the Office Action is incomplete with at least this regard.
`
`Claim 7 includes features similar to those discussed above with respect to claim 1, and
`
`therefore, is patentable for at least similar reasons as those discussed above with respect to
`
`claim 1. Specifically, claim 7 recites “a repair amplifier disposed on the driving circuit chip, and
`
`connected to the repair line and the repair bar”, which is not disclosed or suggested in either Lin
`
`or Sah, alone or in combination. Accordingly, since Lin in view of Sah fails to disclose or
`
`suggest each element of claim 7, the 35 U.S.C. § 103(a) rejection of claim 7 must be withdrawn.
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103(a)
`
`rejection of claims 1 and 7. Claims 2-6 depend from claim 1 and are allowable at least for this
`
`reason. Claims 8-12 depend from claim 7 and are allowable at least for this reason. Since
`
`none of the other prior art of record, whether taken alone or in any combination, discloses or
`
`suggests all the features of the claimed invention, Applicant submits that independent claims 1,
`
`7, and all the claims that depend therefrom, are allowable.
`
`Added Claims
`
`Added claim 13 is directed to additional features of the invention, which are not
`
`disclosed or suggested in the art of record.
`
`
`
`Application No.: 12/547,849
`Reply dated June 13, 2012
`Response to Office Action of March 16, 2012
`
`W
`
`A full and complete response has been made to the pending Office Action, and all of the
`
`stated grounds for rejection have been overcome or rendered moot. Accordingly, all pending
`
`claims are allowable, and the application is in condition for allowance.
`
`The examiner is invited to contact Applicant’s undersigned representative at the number
`
`below if it would expedite prosecution. Prompt and favorable consideration of this Reply is
`
`respectfully requested.
`
`Respectfully submitted,
`
`/hae-chan park/
`
`Hae-Chan Park
`
`Reg. No. 50,114
`
`Date: June 13, 2012
`
`CUSTOMER NUMBER: 58027
`
`H.C. Park & Associates, PLC
`8500 Leesburg Pike
`Suite 7500
`
`Vienna, VA 22182
`Tel: 703-288-5105
`Fax: 703-288-5139
`HCP/SKH/cel
`
`"10--
`
`

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