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`Status of Claims
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`Independent Claim 92 has been amended to correct a minor typographic error and
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`independent claim 99 has been added. Claims 21-99 are presently pending.
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`Claim Rejections — 35 USC § 112
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`Claims 21, 76, 92, and all of their dependent claims stand rejected as allegedly
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`indefinite under 35 U.S.C. § 112 111 (pre-AIA). Specifically, the Examiner alleges that the
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`preamble phrase “A polarization conversion system operable to direct time-sequential left
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`and right stereo images onto an overlapping area of a cinema projection screen” does not
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`comply with the written description requirement.
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`The Final Office Action (FOA) maintained the 112111 rejection first raised in the non-
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`final office action dated Oct. 9, 2019, rejecting independent claims 21, 76 and 92, alleging
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`that the recitation in the claim preamble of "A polarization conversion system operable to
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`direct time-sequential left and right stereo images onto an overlapping area of a cinema
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`projection screen" does not appear to be part of the original disclosure. The FOA maintained
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`the allegation that “since there is no mentioning of time sequential left and right stereo
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`images and how these images work in conjunction with system as claimed, the claims do not
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`appear to comply with 35 U.S.C. 112111. Applicant respectfully disagrees for the following
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`reasons:
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`A. APPLICANT WAS CLEARLY IN POSSESSION OF THE CLAIMED
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`INVENTION AT THE TIME OF FILING
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`1. Applicant has demonstrated how the specification EXPLICITLY teaches
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`directing time-seguential left and right stereo images onto an overlapping area of
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`a cinema projection screen
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`Applicant initially responded to this rejection by illustrating with eXplicit references to
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`how the specification taught directing time-sequential left and right stereo images onto an
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`overlapping area of a cinema projection screen. In response, the FOA clarified and
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`19
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`
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`maintained the rejection, stating that the Office takes the position that ray-bundle and im_age
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`are not the same.
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`Applicant thanks the Examiner for clarifying this rejection, but respectfully submits that
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`the terms “ray bundle” and “image” are used somewhat synonymously to describe the
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`technical concepts set out in the specification, and as presently claimed.
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`The specification both explicitly and implicitly discloses directing time-sequential left-
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`and right- stereo images onto an overlapping area of a cinema projection screen. Just
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`because the projection of stereoscopic images may be described in terms of ray bundles in
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`the specification to teach or demonstrate the technical concepts therein, it does not prevent
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`the applicant from claiming the invention in terms that a Person of Ordinary Skill In The Art
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`(POSITA) would clearly understand.
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`While Applicant respectfully believes a clear explanation has already been explicitly
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`provided as to how the claimed subject matter is described in the specification, and
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`respectfully refers the Examiner to the explanation in the response to the non-final office
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`action for such explicit disclosure.
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`2. Applicant herein provides demonstration how the specification also
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`IMPLICITELY teaches directing time-seguential left and right stereo images
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`onto an overlapping area of a cinema projection screen
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`Implicitly, Applicant also described a technical problem with reference to a conventional
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`time-sequential left and right stereoscopic (or stereo) image projection system described in
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`the commonly-owned US4,792,850 patent to Liptoh (“Liptoh ‘850”), as incorporated by
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`reference, and briefly described in Figure l of Applicant’s original disclosure. Using Liptoh
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`‘850 as a reference that a POSITA would have in their possession, they would understand the
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`general concept of stereoscopic images projected time-sequentially toward a screen and the
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`use of polarization decoding eyewear to view such imagery. For instance, Applicant
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`described the operation of Liptoh’s conventional system of Fig. 6 in Liptoh ”850 with
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`reference to “ray bundles” yet the Liptoh ‘850 reference calls similar light output through the
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`same system a “projected image” (Liptoh ‘850, Col. 10, In 33). For example:
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`20
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`
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`[0004}
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`Ray bundles A, B, and C in FEG. l are bundles forming spots at the
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`bottom, center, and top of a screen 14, respectively.
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`Applicant uses similar terminology when describing embodiments of the presently claimed
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`polarization control system:
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`[0029] With reference to FlGS. 2 and 3, theo A’, B’, and C."
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`should substantially overlap then B, and C; for viewing
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`comfort (although perfect overlap is not necessarily required).
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`(emphasis added)
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`Applicant also described the technical deficiencies of Liptoh ‘850 and how the present
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`application addresses such deficiencies. Accordingly, Applicant has demonstrated (and a
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`POSITA would understand) that the ray bundles are components of a projected im_age and
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`are operationally related (noting that different inventors often use different terms and words
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`to describe similar technology), and therefore Applicant was clearly in possession of the
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`claimed subject matter, as understood by a POSITA, at the time of filing.
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`3. A Person of Ordinary Skill in the Art at the time of filing would understand that
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`images in cinema are formed by projecting ray bundles toward a screen.
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`While light ray bundles have been used for illustration in the specification, the Applicant
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`is not limited by the term “ray bundle” in the specification, particularly given the common
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`understanding in the cinematic arts that projected images are technically synonymous with a
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`plurality of ray bundles projected on a screen, and there is nothing in Applicant’s
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`specification saying otherwise.
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`Based on the above, the phrase “time-sequential left and right stereo images onto an
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`overlapping area of a cinema projection screen” is clearly supported in the original disclosure
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`in connection with 35 U.S.C. 1121ll, and accordingly the rejection of claims 21-98 under this
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`subsection is overcome. Applicant respectfully requests withdrawal of this rej ection.
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`21
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`
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`B. APPLICANT HAS PARTICULARLY POINTED OUT AND
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`DISTINCTLY CLAIMED THE SUBJECT MATTER REGARDED AS
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`APPLICANT’S INVENTION
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`Based on this same language, the FOA rejects claims 21-98 under 35 U.S.C. 112 112
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`(pre-AIA) as being allegedly indefinite for failing to particularly point out and distinctly
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`claim the subject matter which the inventor or a joint inventor regards as the invention.
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`Applicant trusts that the above careful explanations adequately address the Examiner’s
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`concern of how the time-sequential left and right stereo images are employed in the claimed
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`subject matter. Specifically, the left and right stereo images may be time-sequentially
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`encoded in alternating frames using orthogonal polarization states (as an example) as
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`illustrated with reference to Figure 2 of the present Application.
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`Regarding the limitation of “diverging image light,” one of ordinary skill in the art
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`understands that light emitted from a projection lens toward a projection screen is diverging
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`image light, as the projection lens is a convex lens that is designed to project an image onto a
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`large projection screen. This diverging light is understood to be contrasted from converging
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`light or collimated light. The diverging light is clearly illustrated as an example in Figure 2,
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`with light bundles emerging from projection lens 122, passing through the PCS 100 as
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`diverging light bundles (as seen from light bundles A, B, C and A’, B’, C’), to be projected
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`on screen 130. Thus, Applicant respectfully submits that a POSITA would clearly
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`understand the scope of the claims and the recited limitation “diverging image light”.
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`Page 4 of the FOA states that the Examiner understands that there “does not appear to
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`be an overlapping of time-sequential left and right stereo images overlapping on the
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`projection screen.” Not so. Applicant respectfully submits that the left- and right-stereo
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`images are time-sequentially projected onto an “overlapping m” (emphasis added) of the
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`projection screen, as recited in the claim preamble, and as supported by the following text in
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`the Applicant’s specification:
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`22
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`
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`[0021}
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`The poierization switch 120, acting on p—poiarized ray hundies A", B',
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`and C', rotates the poiarization of the ray hundieso _i_r_1
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`synchronization with the rotation of hundies A, B, and C, The position of
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`hundies A", B”, and C' at the screen may he adjusted (e.g., by adjusting the
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`tiit ef the foid mirrer 116) to cioseiy er exactiy coincide with the positions of
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`hundies A, B, and C at the screen. Since neariy aii of the randomiy poiarized
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`Eight 106 from the projection tens 122 is imaged at the screen 130 with a sihgie
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`poiarization state, the resuiting image of the system in PEG. 2 is approximateiy
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`two times brighter than the image at the screen for the system in HS. 1.
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`(emphasis added)
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`See Also 1] [0029].
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`It should be noted that while the office action discusses orthogonal P- and S-
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`polarization states (which are typically linear polarization states) as examples of polarization
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`encoding, Applicant wishes to make clear that any other orthogonal polarization states may
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`be used with the presently claimed polarization conversion system, including but not limited
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`to, left- and right-handed circular polarization.
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`Furthermore, Applicant disagrees with the FOA’s technical characterization on FOA
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`Page 4, stating that “left and right stereo images are formed only after passing through
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`eyewear and enter[ing] view’s eye.” (emphasis added). As taught in the specification para
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`[0021], the polarization switch acts on (e. g., translates the polarization state) of alternating
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`image frames (e.g., left, right, left, right, left, right, left, right, etc.) in synchronization with
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`left and right image frames received from the projector and encodes the respective
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`alternating frames with states of polarization associated with the left or right eye polarization
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`states. See also, description of polarization switch of Liptoh ‘850, as incorporated by
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`reference, and further, as Applicant described in para [0004]:
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`[0004] The polarization switch 30 is synchronized with the image frame, and
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`the polarization state 24 emerging from the poiarization switch is aiternated,
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`23
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`
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`producing images of attematety arthogonat potarizatien at the screen,
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`Polarization-selective eyewear attows images of one polarization to pass to
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`the iett eye, and images of the orthogonat poiarizatien to pass to the right eye.
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`By presenting different images to each eye, 35:) imagery can be synthesized.
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`It should be clear to a POSITA that left stereo images are an image set that is for presentation
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`to a left eye and right stereo images are an image set that is for presentation to a right eye.
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`These left/right stereoscopic image sets are typically provided to a projector for projection,
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`and a POSITA would understand that they are not formed only after passing through
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`eyewear.
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`Based on the above, Applicant has particularly pointed out and distinctly claimed the
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`subject matter which the inventor or a joint inventor regards as the invention. Accordingly,
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`the rejection of claims 21-98 under 35 U.S.C. 112 1T2 is overcome. Applicant respectfully
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`requests Withdrawal of this rej ection.
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`24
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`
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`CONCLUSION
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`Based on the above remarks, Applicant respectfully submits that all pending claims
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`are in condition for allowance. The Commissioner is hereby authorized to charge any fees
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`required by this response to our Deposit Account No. 50-6262 (Attorney Docket No.
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`229501). Should the examiner have any questions or comments regarding this matter, the
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`undersigned may be contacted at the below listed telephone number.
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`Date: October 30, 2020
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`Respectfully Submitted,
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`/Neil G. J. Mothew: Reg. No. 54922/
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`Neil G. J. Mothew, Reg. No. 54,922
`Ashfields Law PC
`
`5090 E Perry Pkwy
`Greenwood Village, CO 80121
`Telephone: (469) 879-3879
`nm 0th ew filash'fi eldsi aw .com
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`25
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