Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
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`REMARKS
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`Claims 1 and 7 have been amended and new claims 21 and 22 have been added.
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`Accordingly, claims 1-22 are currently pending in the Application, of which claims 1 and 7 are
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`independent
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`Applicant respectfully submits that the above amendments are for clarification purpose
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`only, and therefore, do not add new matter to the Application and are fully supported by the
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`specification. Support for the amendments and added claims may be found at least in Figure 3
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`and at relevant pages of the specification.
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`In view of the above amendments and the following Remarks, Applicant respectfully
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`requests reconsideration and timely withdrawal of the pending objections and rejections for the
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`reasons discussed below.
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`Amendments to the Drawings
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`Attached is a replacement figure sheet for FIG. 2, which includes the changes, without
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`markings. FIG. 2 has been amended to provide proper reference character NA for the non-
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`display area.
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`Claim Objection
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`Claims 1 and 7 were objected to for the informalities.
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`Claims 1 and 7 have been amended for clarification and not for the purpose of avoiding
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`prior art or narrowing the claimed subject matter. Thus, no change in claim scope is intended,
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`and Applicant does not intend to relinquish any subject matter by these amendments. Applicant
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`respectfully submits that claims 1 and 7, as amended, overcome the stated objection.
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`Accordingly, Applicant respectfully requests withdrawal of the objection for claims 1 and 7.
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`

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`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
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`Rejections under 35 U. S. C. § 103
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`Claims 1-3, 6-8, and 20 stand rejected under 35 U.S.C. § 103 as allegedly being
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`unpatentable over US. Patent Application Publication No. 2016/0366379, applied for by Hickl
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`(“Hickl”)
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`in view of US. Patent Application Publication No. 2016/0178940, applied for by Yuan
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`et al. (“Yuan”). Applicant respectfully traverses these rejections for at least the following
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`reasons.
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`To establish an obviousness rejection under 35 U.S.C. § 103, four factual inquiries must
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`be examined. The four factual inquiries include (a) determining the scope and contents of the
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`prior art; (b) ascertaining the differences between the prior art and the claims in issue; (c)
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`resolving the level of ordinary skill in the pertinent art; and (d) evaluating evidence of secondary
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`consideration. Graham v. John Deere, 383 US. 1, 17-18 (1966).
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`In view of these four factors, the analysis supporting a rejection under 35 U.S.C. § 103
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`should be made explicit, and should “identify a reason that would have prompted a person of
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`ordinary skill in the relevant field to combine the [prior art] elements" in the manner
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`claimed. KSR Int’l. Co. v. Teleflex, Inc., 127 S. Ct. 1727, 82 USPQ2d 1385, 1396 (2007). The
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`Federal Circuit requires that "rejections on obviousness cannot be sustained with mere
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`conclusory statements; instead, there must be some articulated reasoning with some rational
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`underpinning to support the legal conclusion of obviousness." In re Kahn, 441 F.3d 977, 988,
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`78 USPQ2d 1329, 1336 (Fed. Cir. 2006).
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`Finally, even if the prior art may be combined, there must be a reasonable expectation of
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`success, and the reference or references, when combined, must disclose or suggest every
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`claimed feature. See In re Vaeck, 947 F.2d 488, 20 USPQ2d 1438 (Fed. Cir. 1991).
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`A.
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`Claim 1
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`-10-
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`

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`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
`
`Applicant has, merely in the interests of advancing prosecution and without conceding to
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`any of the arguments presented in the Office Action, amended independent claim 1 to recite,
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`inter alia:
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`a plurality of display modules, each of the display modules
`comprising:
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`a display area comprising:
`a first sub-area comprising at least one first pixel unit; and
`at least one second sub-area disposed to adjoin and to
`surround the first sub-area, the at least one second sub-area
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`comprising at least one second pixel unit; and
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`wherein each of the at least one first pixel unit and the at least one
`second pixel unit comprises:
`a first pixel configured to display a first color;
`a second pixel configured to display a second color; and
`a third pixel configured to display a third colors, the first, second,
`and third colors being different from each another, and
`wherein the at least one second pixel unit further comprises:
`at least one fourth pixel configured to display a white color.
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`(Emphasis added). The Office Action alleges that Hickl discloses the first sub-area and
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`at least one second sub-area of claim 1, and that since the fourth sub-pixel W of Yuan discloses
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`the fourth pixel configured to display a white color, Hickl in view of Yuan discloses the above
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`features of claim 1 sans the amendment. Office Action, at 4-5. As will become more apparent
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`below, even if combined, Hickl and Yuan fail to teach or suggest each and every one of the
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`above-noted features of claim 1 as amended.
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`First, paragraphs [0028] and [0029] of Hickl provides the following advantage of the
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`invention:
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`[0028] An advantage of some embodiments is that the impact of thermal and
`humidity expansion and the relative movement of tiles with respect to each
`other on the inter-tile seams can be reduced. This allows the use of thin brittle
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`substrates and reduces weight of components.
`[0029] An advantage of some embodiments is that the installation effort can be
`reduced. An advantage of some embodiments is that projectors require less
`readjustment if environmental conditions are changing.
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`-11-
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`

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`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
`
`(Emphasis added). More particularly, to maintain “the distance between two adjacent
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`tiles is less than the size of a pixel location on the display screen,” id., paragraph [0048], “the
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`coefficient of thermal expansion of the first substrate is less than the coefficient of thermal
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`expansion of the at least one first layer and the distance between the at least two tiles is less
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`than the size of a pixel on the display screen.” ld., paragraph [0030].
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`In other words, Hickl
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`merely discloses the correlation between the first substrate 1, the polymer layer 3, the second
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`substrate 2, and the second layer 6, including the distances and coefficients of thermal
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`expansion. See id., FIGS. 3, 4A, 4B, 5, 8, 9, and 11. Therefore, Hickl fails to provide any
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`evidence of the first sub-area and at least one second sub-area disposed in each tile, other than
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`the arbitrary distinction made by the Office Action.
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`Next, Yuan discloses color filter substrate that may reduce “ajaggies phenomenon [and]
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`a color cast phenomenon .
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`.
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`. in an image displayed by the display device” Yuan, paragraph
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`[0066] having “non-rectangular shape such as a parallelogram, a trapezoid, an oval or a
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`circularity.” ld., paragraph [0031]. Accordingly, Yuan provides various embodiments of color
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`filter substrate including the one illustrated in FIG. 6, disposed in the peripheral display regions.
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`See id., FIG. 6. However, Yuan also discloses that “the peripheral display regions provided in
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`embodiments of the disclosure may correspond to different peripheral shapes of display regions,
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`which applies to other embodiments of the disclosure.” ld., paragraph [0041].
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`In other words,
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`Yuan specifically discloses, for a display having non-rectangular shape, the color filter disposed
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`in the peripheral display regions corresponding to shapes of display region having non-
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`rectangular shape, may have an embodiment illustrated in FIG. 6, which includes the fourth sub-
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`pixel W. Yuan provides that “the display region 20 includes a peripheral display region 21
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`adjacent to the non-display region 23,” id., paragraph [0031], but it fails to provide any evidence
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`that the peripheral display region 21 surrounds the central display region 22, other than the
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`incidental features illustrated in the drawings. Therefore, Applicant respectfully submits that,
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`

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`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
`
`even if combined, Hickl and Yuan fail to disclose or suggest every claimed feature of claim 1 as
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`amended.
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`Furthermore, Applicant respectfully submits that the Office Action fails to provide a
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`persuasive reason to combine Hickl and Yuan in the manner claimed. When evaluating claims
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`for obviousness, “the prior art as a whole must be considered. The teachings are to be viewed
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`as they would have been viewed by one of ordinary skill.” In re Hedges, 783 F.2d 1038, 1041
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`(Fed. Cir. 1986). Thus, “‘[i]t is impermissible within the framework of section 103 to pick and
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`choose from any one reference only so much of it as will support a given position, to the
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`exclusion of other parts necessary to the full appreciation of what such reference fairly suggests
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`to one of ordinary skill in the art.”’ Id. (quoting In re Wesslau, 353 F.2d 238, 241 (CCPA)).
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`First, Hickl specifically discloses that the tiles of the display panel are rectangular shape.
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`See Hickl, FIGS. 2 and 4A. This is self-evident from the disclosure of Hickl that one of the
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`advantage of the embodiments is reduced installation effort. See id., paragraph, [0029]. On the
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`other hand, Yuan specifically discloses, as proffered,
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`that the color filter embodiments are
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`disposed in the peripheral display region 21 corresponding to shapes of display region having
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`non-rectangular shape to reduce the jaggies phenomenon and the color cast phenomenon.
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`Therefore, when Hickl and Yuan are each considered as a whole, not only that Hickl provides
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`no evidence of display region having non-rectangular shape, Both of Hickl and Yuan provide no
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`reason why the invention of Yuan directed to reducing the jaggies phenomenon and the color
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`cast phenomenon in the display region having non-rectangular shape to be combined to the
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`rectangular shaped tiles of Hickl. Thus, it is impermissible within the framework of section 103
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`to pick and choose from Hickl and Yuan only so much of them as will support the combination of
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`Hickl and Yuan in the manner claimed, to the exclusion of other parts necessary to the full
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`appreciation of what Hickl and Yuan fairly suggest to one of ordinary skill in the art.
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`B.
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`Claim 7
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`-13-
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`

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`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
`
`Applicant has, merely in the interests of advancing prosecution and without conceding to
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`any of the arguments presented in the Office Action, amended independent claim 7 to recite,
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`inter alia:
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`wherein each of the at least one first pixel unit, the at least one second
`pixel unit, the at least one third pixel unit, the at least one fourth pixel unit, and
`the at least one fifth pixel unit comprises:
`a first pixel configured to display a first color;
`a second pixel configured to display a second color; and
`a third pixel configured to display a third color, the first, second,
`and third colors being different from one another, and
`wherein each of the at least one second pixel unit, the at least one
`third pixel unit, the at least one fourth pixel unit, and the at least one fifth
`pixel unit further comprises:
`at least one fourth pixel configured to display a white color.
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`(Emphasis added) The Office Action rejected claim 7, sans the amendment, for the
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`same reasons proffered regarding claim 1 sans the amendment. See Office Action, at 6-8.
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`Applicant respectfully submits that, for substantially the identical reasons proffered regarding
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`claim 1 as amended, even if combined, Hickl and Yuan fail to disclose or suggest every
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`claimed feature of claim 7 as amended, and that the Office Action fails to provide a persuasive
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`reason to combine Hickl and Yuan in the manner claimed.
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
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`of claims 1 and 7. Claims 2, 3, 6, 8, and 20 depend from claims 1 and 7 and are allowable at
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`least for this reason. Since none of the alleged prior art of record, whether taken alone or in any
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`combination, discloses or suggests all the features of the claimed subject matter, Applicant
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`submits that independent claims 1 and 7, and all the claims that depend therefrom, are
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`allowable.
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`Claims 4, 5, 9-15, 18 and 19 stand rejected under 35 U.S.C. § 103 as allegedly being
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`unpatentable over Hickl
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`in view of Yuan, as applied to claim 1 above, further in view of US.
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`-14-
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`

`

`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
`
`Patent Application Publication No. 2013/0027439, applied for by Kim et al. (“Kim”). Applicant
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`respectfully traverses these rejections for at least the following reasons.
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`Applicant respectfully submits that claims 1 and 7 are allowable over Hickl and Yuan,
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`and Kim fails to cure the deficiencies of Hickl and Yuan noted above with regard to claims 1 and
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`7. Hence, claims 4, 5, 9-15, 18 and 19 are allowable at least because they depend from
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`allowable claims 1 and 7. Accordingly, Applicant respectfully requests withdrawal of the 35
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`U.S.C. § 103 rejection of claims 4, 5, 9-15, 18 and 19.
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`Claim 16 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over
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`Hickl
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`in view of Yuan, further in view of Kim, further in view of US. Patent No. 6,014,121,
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`issued to Aratani et al. (“Aratani”). Applicant respectfully traverses this rejection for at least the
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`following reasons.
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`Applicant respectfully submits that claim 7 is allowable over Hickl and Yuan, and Kim
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`and Aratani fail to cure the deficiencies of Hickl and Yuan noted above with regard to claim 7.
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`Hence, claim 16 is allowable at least because they depend from an allowable claim 7.
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection of claim
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`16.
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`Claim 17 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over
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`Hickl
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`in view of Yuan, further in view of Kim, further in view of Aratani, further in view of US.
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`Patent Application Publication No. 2014/0211103, applied for by Baek et al. (“Baek”). Applicant
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`respectfully traverses this rejection for at least the following reasons.
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`Applicant respectfully submits that claim 7 is allowable over Hickl and Yuan, and Kim,
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`Aratani, and Baek fail to cure the deficiencies of Hickl and Yuan noted above with regard to
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`claim 7. Hence, claim 17 is allowable at least because they depend from an allowable claim 7.
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`-15-
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`

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`Application No.: 16/102,615
`Reply dated December 31,2019
`Response to Office Action of October 3, 2019
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection of claim
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`17.
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`Added Claims
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`Added claims 21 and 22 are directed to additional features of the disclosed subject
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`matter, which are not disclosed or suggested in the art of record. Applicant respectfully submits
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`that claims 21 and 22 are allowable at least because they depend from allowable claims 1 and 7
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`W
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`A full and complete response has been made to the pending Office Action, and all of the
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`stated objections and grounds for rejection have been overcome or rendered moot.
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`Accordingly, all pending claims are allowable, and the Application is in condition for allowance.
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`The Examiner is invited to contact Applicant’s undersigned representative at the number
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`below if it would expedite prosecution. Prompt and favorable consideration of this Reply is
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`respectfully requested.
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`Respectfully submitted,
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`/jin hoon lee/
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`Jin Hoon Lee
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`Reg. No. 78,678
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`Date: December 31, 2019
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`CUSTOMER NUMBER: 58027
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`HO. Park & Associates, PLC
`1894 Preston White Drive
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`Reston, VA 20191
`Tel: 703-288-5105
`Fax: 703-288-5139
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`CBK/JHL/hmb/sj
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`-16-
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`