Application No.: 16/114,040
`Reply dated November 19, 2019
`Response to Office Action of August 21, 2019
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`REMARKS
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`Claims 1 and 11 have been amended. Accordingly, claims 1-20 are currently pending in
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`the Application, of which claims 1 and 11 are independent.
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`Applicants respectfully submit that the above amendments do not add new matter to the
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`Application and are fully supported by the specification. Support for the amendments may be
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`found at least in Figure 5 and supporting paragraphs of the specification.
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`In view of the above amendments and the following Remarks, Applicants respectfully
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`request reconsideration and timely withdrawal of the pending objections and rejections for the
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`reasons discussed below.
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`Claim Objection
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`Claim 1 was objected to because claim 1, line 11, recites “the second insulating layer”,
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`and there is no antecedent basis for the second insulating layer; only a first insulating layer is
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`recited.
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`Claim 1 has been amended to delete this recitation. Applicants respectfully submit that
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`claim 1, as amended, overcomes the stated objection. Accordingly, Applicants respectfully
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`request withdrawal of the objection for claim 1.
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`Rejections Under 35 U. S. C. § 103
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`Claims 1-3, 6-13, and 16-20 stand rejected under 35 U.S.C. § 103 as allegedly being
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`unpatentable over US. Patent Application Publication No. 2004/0109102, applied for by Chang,
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`et al. (“Chang”) in view of US. Patent Application Publication No. 2018/0076233, applied for by
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`Park (“Park”). Applicants respectfully traverse this rejection for at least the following reasons.
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`Application No.: 16/114,040
`Reply dated November 19, 2019
`Response to Office Action of August 21, 2019
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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. §
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`103(a) should be made explicit, and should “identify a reason that would have prompted a
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`person of 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 USPQZd 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 USPQZd 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 USPQZd 1438 (Fed. Cir. 1991).
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`On page 3 of the Office Action, the Examiner relies on gate line 102 shown in FIG. 5| to
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`teach the claimed first connection electrode, and on gate pad 122 shown in FIG. 5| to teach the
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`claimed second connection electrode. As can be seen from FIG. 5| of Chang (shown below),
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`gate line 102 and gate pad 122 are disposed on different layers.
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`Application No.: 16/114,040
`Reply dated November 19, 2019
`Response to Office Action of August 21, 2019
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`FIG. 5| of Chang
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`Park fails to cure this deficiency in Chang. Thus, the combination of Chang and Park
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`fails to disclose at least the following features recited in claim 1, as amended:
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`wherein the first connection electrode and the second connection electrode are
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`disposed on the same layer.
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`
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`Application No.: 16/114,040
`Reply dated November 19, 2019
`Response to Office Action of August 21, 2019
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`as 123:3;
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`1‘20
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`<Annotated Fig. 5 of the present invention:-
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`Accordingly, the floating electrode FE may at least pattially overlap the first connection "“
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`electrode CNE1 and? the second connection electrode CNE2
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`As shown in Fig. 5 and paragraph [0110] of the present invention, the floating electrode
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`FE overlaps the first and second connection electrodes CNE1 and CNE2 in a plan view.
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`However, Park explicitly discloses that barrier pattern 212 is disposed on substrate 111,
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`as shown in FIG. 7 illustrated below.
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`Park fails to disclose that the barrier pattern 212 overlaps elements corresponding to the
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`first and second connection electrodes of claimed invention. Thus, the combination of Chang
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`and Park fails to disclose at least the following features recited in claim 11, as amended:
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`10
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`Application No.: 16/114,040
`Reply dated November 19, 2019
`Response to Office Action of August 21, 2019
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`wherein the floating electrode overlaps the first and second connection
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`electrodes in a plain view.
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`Accordingly, Applicants respectfully request withdrawal of the 35 U.S.C. § 103 rejection
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`of claims 1 and 11. Claims 2, 3, 6-10, 12, 13, and 16-20 depend from claims 1 and 11, and are
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`allowable at least for this reason. Since none of the alleged prior art of record, whether taken
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`alone or in any combination, discloses or suggests all the features of the claimed subject matter,
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`Applicants respectfully submit that independent claims 1 and 11, and all the claims that depend
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`therefrom, are allowable.
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`Claims 4, 5, 14, and 15 stand rejected under 35 U.S.C. § 103 as allegedly being
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`unpatentable over Chang and Park, as combined above in regard to claims 1 and 11, in further
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`view of US. Patent Application Publication No. 2015/0370116, applied for by Chae, et al.
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`(“Chae”). Applicants respectfully traverse this rejection for at least the following reasons.
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`Applicants respectfully submit that claims 3 and 13 are allowable over Chang and Park,
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`and Chae fails to cure the deficiencies of Chang and Park noted above with regard to claims 3
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`and 13. Hence, claims 4, 5, 14, and 15 are allowable at least because they depend from
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`allowable claims 3 and 13.
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`Accordingly, Applicants respectfully request withdrawal of the 35 U.S.C. § 103 rejection
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`of claims 4, 5, 14, and 15.
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`11
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`Application No.: 16/114,040
`Reply dated November 19, 2019
`Response to Office Action of August 21, 2019
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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 Applicants’ 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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`NVilliam L. Brooksl
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`Vlfilliam L. Brooks
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`Reg. No. 34,129
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`Date: November 19, 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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`HCPNVLB/emp/jhc
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