Reply to Office Action of May 17, 2019
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`Remarks
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`Stephen HODGE
`Application No. 15/491,728
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`Reconsideration of this Application is respectfully requested.
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`Upon entry of the foregoing amendment, claims 1-2, 4-8 and 10-22 are pending in the
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`application, with claims 1, 17, and 20 being the independent claims. Claims 1, 6, 7, 10, 11, 17, 20,
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`and 22 are sought to be amended. Support for these amendments may be found at, for example,
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`paragraphs 76-78 of the instant specif1cation. These changes are believed to introduce no new
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`matter, and their entry is respectfully requested.
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`Based on the above amendment and the following remarks, Applicant respectfully requests
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`that the Examiner reconsider all outstanding objections and rejections and that they be withdrawn.
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`Rejections under 35 U.S.C. § 103
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`Claims 1, 2, 4-8 and 10-22 are rejected under 35 U.S.C. 103 as being unpatentable over Lee
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`(US 2013/0197718) in view of Solomon (US 2004/0030449). Applicant traverses.
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`Lee and Solomon, either singularly or in combination, fail to teach or suggest the features
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`associated with the mobile correctional facility robot performing a delivery task as recited in the
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`independent claims. For example, Lee and Solomon fail to teach or suggest at least “receiving,
`77 (4
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`based on the delivery task, a delivery item and a delivery destination,
`77 (4
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`authenticating the delivery
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`item,
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`securing, in response to the authenticating, the delivery item using one or more of the
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`plurality of actuators,
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`transporting the delivery item to the delivery destination,” and “performing
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`a second authentication of the delivery item prior to delivering the delivery item,” as recited in
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`claim 1, and as similarly recited in claims 17 and 20.
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`Atty. Dkt. No. 3210.1400000
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`Reply to Office Action of May 17, 2019
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`Stephen HODGE
`Application No. 15/491,728
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`In rejecting the language “performing one of a monitoring action, a delivery action, and an
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`enforcement action” in claim 1, the Office Action relies on figures 8-15 and paragraphs 87-90 of
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`Lee. (Office Action, 4). Specifically, the Office Action alleges these citations disclose the “acquire
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`image, sound alarm, [and] drive robot in many directions” functions. However, these citations do
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`not disclose Lee’s robot as performing a delivery task. For example, paragraph 87 describes a
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`“manual surveillance mode,” paragraph 88 describes “a mode transition procedure of the robot
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`control terminal,” paragraph 89 describes “diagrams showing autonomous driving,” and paragraph
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`90 describes preventing “correctional accidents such as suicide, assault, arson, vandalism, and the
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`like.” (Lee, 111187-90). And figures 8-15 merely illustrate the various driving modes for performing
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`“unmanned surveillance.” (Lee, 11113 0-3 7). Accordingly, none of the cited portions of Lee teach or
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`suggest the limitations associated with a delivery task as recited in the independent claims.
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`The remainder of Lee is also deficient. There is no disclosure or suggestion of Lee’s robot
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`performing a delivery task that includes “securing, in response to the authenticating, the delivery
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`item using one or more of the plurality of actuators” and “transporting the delivery item to the
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`delivery destination,” and “performing a second authentication of the delivery item prior to
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`delivering the delivery item.” Lee also does not teach or suggest his robot being capable of
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`“authenticating the delivery item” prior to securing the delivery item and then performing a second
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`authentication step prior to delivering the delivery item.
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`Solomon does not cure Lee’s deficiencies. Solomon is directed toward “[u]nmanned
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`underwater vehicles” “for use in a swarm weapon system.” (Solomon, abstract). Solomon does not
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`teach or suggest his vehicles performing a delivery task including the specific steps recited in the
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`independent claims. Like Lee, Solomon’s vehicles are limited to a specific role. Where Lee’s robots
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`Atty. Dkt. No. 3210.1400000
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`Reply to Office Action of May 17, 2019
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`- 10 -
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`Stephen HODGE
`Application No. 15/491,728
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`were configured for “unmanned surveillance [] capable of preventing or early detecting correctional
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`accidents,” (Lee, 116), Solomon’s vehicles are limited to “utilizing a distributed network of mobile
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`robotic vehicles in a centralized way [to] creat[e] a novel and powerful automated weapon system.”
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`(Solomon, 1117.) Accordingly, Solomon does not teach or suggest the limitations associated with a
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`delivery task as recited in the independent claims.
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`For at least these reasons, Lee and Solomon do not teach the claimed mobile correctional
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`facility robot as claimed in the independent claims. Accordingly, withdrawal of the § 103 rejection
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`is respectfully solicited.
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`Atty. Dkt. No. 3210.1400000
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`Reply to Office Action of May 17, 2019
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`- 11 -
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`Stephen HODGE
`Application No. 15/491,728
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`Conclusion
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`All of the stated grounds of rejection have been properly traversed, accommodated, or
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`rendered moot. Applicant therefore respectfully requests that the Examiner reconsider all presently
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`outstanding rejections and that they be withdrawn. Applicant believes that a full and complete reply
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`has been made to the outstanding Off1ce Action and, as such, the present application is in condition
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`for allowance. If the Examiner believes, for any reason, that personal communication will expedite
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`prosecution of this application, the Examiner is invited to telephone the undersigned at the number
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`provided.
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`Prompt and favorable consideration of this Amendment and Reply is respectfully requested.
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`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
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`/Dohm Chankong/
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`Dohm Chankong
`Attorney for Applicant
`Registration No. 70,524
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`Date:
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`September 13, 2019
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`1100 New York Avenue, NW.
`Washington, DC. 20005-3934
`(202) 371-2600
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`132383661
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`Atty. Dkt. No. 3210.1400000
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