Reply to Office Action of October 11, 2019
`
`Application No. 16/125,569
`
`- 7 -
`
`MAZZARELLA er a].
`
`Reconsideration of this Application is respectfully requested.
`
`Remarks
`
`Upon entry of the foregoing amendment, claims 1-201 are pending in the application, with
`
`claims 1, 12, and 19 being independent. Claims 3 and 14 are sought to be amended. Applicant
`
`respectfully reserves the right to prosecute similar or broader claims, with respect to the amended
`
`claims, in the future. These changes are believed to introduce no new matter, and their entry is
`
`respectfully requested.
`
`Based on the above amendment and the following remarks, Applicant respectfully requests
`
`that the Examiner reconsider all outstanding objections and rejections and that they be withdrawn.
`
`Rejections under 35 U.S.C. § 103
`
`Claims 1-3, 12-13, 14, and 19-20 stand rejected under 35 U.S.C. § 103 as allegedly being
`
`unpatentable over US. 9,313,556 to Borel el al. in view of US. Patent Publication No.
`
`2012/0265867 to Boucher el al. in view of US. Patent Publication No. 2006/0121924 to Rengaraju
`
`el a].
`
`Claim 10 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over Borel
`
`er a]. in view of Boucher el al. in view of Rengaraju el al. in view of US. Patent Publication No.
`
`2012/0313755 to Gutierrez el al.
`
`1 While the Final Office Action Summary lists the pending claims as 1-3, 10-14, and 19-20,
`Applicant assumes this was an error as the pending claims are 1-20.
`
`Atty. Dkt. No. 2844.0170004
`
`

`

`Reply to Office Action of October 11, 2019
`
`Application No. 16/125,569
`
`- 8 -
`
`MAZZARELLA el a].
`
`Claim 11 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over Borel
`
`el al. in view of Boucher el al. in view of Rengaraju el al. in view of US. Patent No. 8,581,957 to
`
`Bengtsson er a].
`
`Applicant respectfully traverses. Independent claims 1, 12, and 19 recite features that
`
`distinguish over the applied references. For example, claim 1 recites “transmit the first video feed to
`
`members of the second talk group, wherein members of the first talk group no longer receive the
`
`first video feed.” Claims 12 and 19 recite analogous distinguishing features. None of the applied
`
`references teach or suggest at least the above-noted distinguishing features.
`
`In rejecting claim 1, the Office acknowledges that Borel does not disclose “pre-assign a first
`
`talk group and a second talk group to the first video camera, .
`
`. .transmit the first video feed to
`
`members of the second pre-eXisting talk group, wherein members of the first pre-eXisting talk group
`
`no longer receive the first video feed.” (Office Action, p. 4.)
`
`Boucher does not cure the deficiency of Borel, nor does the Office introduce Boucher to
`
`provide the missing teaching. (Office Action, pp. 4-5.) See also the Amendment and Reply to Office
`
`Action dated May 10, 2019, p. 10 that eXplains why Boucher does not cure the deficiency of Borel.
`
`The Office alleges that Rengaraju provides the missing teaching. Applicant respectfully
`
`disagrees. Nowhere does Rengaraju teach or suggest at least “transmit the first video feed to
`
`members of the second talk group, wherein members of the first talk group no longer receive the
`
`first video feed” as claimed in the context of “pre-assign a first talk group and a second talk group
`
`to the first video camera” as recited in claim 1. Instead, a portion of Rengaraju cited by the Office
`
`indicates that communications takes place with one group at a time: “window 313 can display the
`
`identifier associated with the audio target communication unit or group.” (Rengaraju, [0045],
`
`Atty. Dkt. No. 2844.0170004
`
`

`

`Reply to Office Action of October 11, 2019
`
`Application No. 16/125,569
`
`- 9 -
`
`MAZZARELLA el a].
`
`emphasis added.) Since Rengaraju only communicates with one group at a time, Rengaraju cannot
`
`teach or suggest at least “transmit the first video feed to members of the second talk group, wherein
`
`members of the first talk group no longer receive the first video feed” as claimed in the context of
`
`“pre-assign a first talk group and a second talk group to the first video camera” as recited in claim 1.
`
`The other portions of Rengaraju cited by the Office describes a push to video service, a user
`
`interface, and a cellular telephone handset (Rengaraju, [0015], [0044], [0046], FIGS. 3-4.)
`
`Gutierrez and Bengtsson do not cure the deficiencies of Borel, Boucher, and Rengaraju, nor
`
`has the Office introduced Gutierrez and Bengtsson to teach the above-noted distinguishing feature.
`
`Thus, the combination of Borel, Boucher, Rengaraju, Gutierrez, and Bengtsson taken alone or in
`
`combination, do not teach or suggest at least “transmit the first video feed to members of the second
`
`talk group, wherein members of the first talk group no longer receive the first video feed” as
`
`claimed.
`
`Accordingly, the applied references do not establish a primafacie case of obviousness for
`
`claim 1. Independent claims 12 and 19 recite analogous features as claim 1 and thus are also
`
`patentable for at least the reasons provided above. Dependent claims 2, 3, 10, 11, 13, 14, and 20 are
`
`also patentable over the applied references at least based on their dependencies from claims 1, 12,
`
`and 19.
`
`Accordingly, Applicant respectfully requests that the Office reconsider and withdraw the
`
`rejections under 35 U.S.C. §103.
`
`Claim Objections/Allowable Subject Matter
`
`Applicant thanks the Examiner for indicating that claims 4 and 15 would be allowable if
`
`rewritten in independent form including all of the limitations of the base claim and any intervening
`
`Atty. Dkt. No. 2844.0170004
`
`

`

`Reply to Office Action of October 11, 2019
`
`Application No. 16/125,569
`
`- lO -
`
`MAZZARELLA er a].
`
`claims, and that dependent claims 5-9 and 16-18 are objected to for their dependency on claims 4
`
`and 15. (Final Office Action, p. 10.) In View of the above amendments, Applicant reserves the right
`
`to make these amendments at a later time.
`
`Atty. Dkt. No. 2844.0170004
`
`

`

`Reply to Office Action of October 11, 2019
`
`Application No. 16/125,569
`
`- ll -
`
`MAZZARELLA er a].
`
`Conclusion
`
`All of the stated grounds of objection and rejection have been properly traversed,
`
`accommodated, or rendered moot. Applicant therefore respectfully requests that the Examiner
`
`reconsider all presently outstanding objections and rejections and that they be withdrawn. Applicant
`
`believes that a full and complete reply has been made to the outstanding Office Action and, as such,
`
`the present application is in condition for allowance. If the Examiner believes, for any reason, that
`
`personal communication will expedite prosecution of this application, the Examiner is invited to
`
`telephone the undersigned at the number provided.
`
`Prompt and favorable consideration of this Amendment and Reply is respectfully requested.
`
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
`
`/Karen Wong-Chan/
`
`Karen Wong-Chan
`Agent for Applicant
`Registration No. 69,235
`
`Date:
`
`Januafl 13, 2020
`
`1100 New York Avenue, NW.
`Washington, DC. 20005-3934
`(202) 371-2600
`1402476171
`
`Atty. Dkt. No. 2844.0170004
`
`