Reply to Office Action of May 10, 2019
`
`Application No. 16/125,569
`
`- 8 -
`
`MAZZARELLA er a].
`
`Reconsideration of this Application is respectfully requested.
`
`Remarks
`
`Upon entry of the foregoing amendment, claims 1-20 are pending in the application, with
`
`claims 1, 12, and 19 being the independent claims. Claims 1-6 and 8-20 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`that the Examiner reconsider all outstanding objections and rejections and that they be withdrawn.
`
`Rejection under 35 U.S.C. § 112
`
`Claims 1-20 stand rejected under 35 U.S.C. § 112(a), as allegedly failing to comply with the
`
`written description requirement.
`
`Without acquiescing to the propriety of the rejections, and solely to expedite prosecution,
`
`claims 1-4, 6, 8, 11-15, and 17-20 have been amended to address the rejections.
`
`Accordingly, reconsideration and withdrawal of the rejection of claims 1-20 under 35 U.S.C.
`
`§ 112 are respectfully requested
`
`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. Patent No. 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. 2007/0054686 to Allen el al.
`
`Atty. Dkt. No. 2844.0170004
`
`

`

`Reply to Office Action of May 10, 2019
`
`Application No. 16/125,569
`
`- 9 -
`
`MAZZARELLA 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 Allen el al. in View of US. Patent Publication No.
`
`2012/0313755 to Gutierrez 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 Allen el al. in View of US. Patent No. 8,581,957 to
`
`Bengtsson er a].
`
`Claims 1, 12-13, 14, and 19-20 stand rejected under 35 U.S.C. § 103 as allegedly being
`
`unpatentable over US. Patent No. 9,313,556 to Borel el al. in View of US. Patent Publication No.
`
`2013/0283330 to Hengeveld in View of US. Patent Publication No. 2016/02273 84 to Mazzarella el
`
`a].
`
`Claim 10 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over Borel
`
`el al. in View of Hengeveld in View of Mazzarella el al. in View of Gutierrez el a].
`
`Claim 11 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over Borel
`
`el al. in View of Hengeveld in View of Mazzarella el al. in View of Bengtsson el al.
`
`Applicant respectfully traverses. Without acquiescing to the propriety of the rejection and
`
`solely to advance prosecution, Applicant has amended the independent claims 1, 12, and 19. The
`
`independent claims recite features distinguishable 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.” Support for the amendment is found in at
`
`least paragraph [0060] of the originally-filed specification. Claims 12 and 19 recite analogous
`
`distinguishing features. None of the applied references teach or suggest at least the above-noted
`
`distinguishing features.
`
`Atty. Dkt. No. 28440170004
`
`

`

`Reply to Office Action of May 10, 2019
`
`Application No. 16/125,569
`
`- 10 -
`
`MAZZARELLA er a].
`
`In rejecting claim 1, the Office acknowledges that Borel does not disclose “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, pp. 5, 12-13.)
`
`Boucher does not cure the deficiency of Borel. For example, Boucher is directed to inviting
`
`resources to join one talk group or incident, to communicate in the event of a disaster (Boucher,
`
`[150]): “A GUI 100 (FIG. 7) is utilized by an IWS controller 22 for selection of another IWS
`
`controller to invite to an incident 72 or peer-to-peer talk group.” (Boucher, [0053], emphasis
`
`added.) So while Boucher adds a video stream to a first talk group (Boucher, [0071], emphasis
`
`added), Boucher does not teach or suggest at least a “second talk group” as claimed. Thus, Boucher
`
`does 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. Other
`
`portions of Boucher cited by the Office describe a block diagram of an Interoperability Workstation
`
`(IWS) controller, an interoperable communications network, and a bidirectional audio stream.
`
`(Boucher, FIG. 3, [0041], [0055].)
`
`Allen does not cure the deficiencies of Borel and Boucher. Allen is directed to providing
`
`PTT data buffering support indications and buffering control. (Allen, Title.) The portions of Allen
`
`cited by the Office are directed to a mobile station for PTT communications that may include
`
`“video, or video plus audio.” (Allen, [0056]). But, Allen’s mobile station for PTT is not a “system
`
`for video management with Push To Talk (PTT)” as recited in claim 1 that “pre-assign[s] a first talk
`
`group and a second talk group to the first video camera” as recited in claim 1 and “transmit[s] 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. Instead, Allen’s mobile station for PTT merely
`
`Atty. Dkt. No. 28440170004
`
`

`

`Reply to Office Action of May 10, 2019
`
`Application No. 16/125,569
`
`- 11 -
`
`MAZZARELLA er a].
`
`changes from one talk group to another: “An end user may select one group from the list to initiate
`
`an instant group talk session or a chat group talk session.” (Allen, [0050].) Thus, Allen does not
`
`teach or suggest at least the above-noted distinguishing feature.
`
`The Office also acknowledges that Borel in view of Hengeveld does not teach “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. 13.)
`
`The Office, however, alleges that “Mazzarella discloses the above limitation (Paragraph 12-
`
`15, 26-27, 38, 42, 44, 46, and 49, add user to different groups “reads on preexisting group, add,
`
`delete from group "no longer receive the video”. (Office Action, p. 13.)
`
`Applicant respectfully disagrees. Mazzarella is directed to intelligent formation and
`
`management of dynamic talk groups. Mazzarella’s PTT users may be invited to join a talk group to
`
`receive a video stream, and they may leave a talk group. (Mazzarella, [0026]). But a PTT user
`
`joining and leaving a talk group is not the same as a “system for video management with Push To
`
`Talk (PTT)” as recited in claim 1 that “pre-assign[s] a first talk group and a second talk group to the
`
`first video camera” as recited in claim 1 and “transmit[s] 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. Thus, Mazzarella does not teach the above-noted distinguishing feature.
`
`Other portions of Mazzarella cited by the Office describe a “discretionary sharing
`
`mechanism based on invitation and acceptance that allows for dynamic publication or sharing of
`
`information in real time among agencies responding to an incident, where the agencies may
`
`establish secure communications,” an agency PTT application, dynamic access permission, talk
`
`Atty. Dkt. No. 28440170004
`
`

`

`Reply to Office Action of May 10, 2019
`
`Application No. 16/125,569
`
`- 12 -
`
`MAZZARELLA er a].
`
`group module, and geotalk groups. (Mazzarella, [0014], [0027], [0038], [0042], [0044], [0046],
`
`[0049].)
`
`Gutierrez and Bengtsson do not cure the deficiencies of Borel, Boucher, Allen, Hengevelt,
`
`and Mazzarella, nor has the Office introduced Gutierrez and Bengtsson to teach the above-noted
`
`distinguishing feature. Thus, the combination of Borel, Boucher, Allen, Hengevelt, Mazzarella,
`
`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
`
`claims.
`
`Atty. Dkt. No. 28440170004
`
`

`

`Reply to Office Action of May 10, 2019
`
`Application No. 16/125,569
`
`- 13 -
`
`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 Off1ce 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:
`
`September 10, 2019
`
`1100 New York Avenue, NW.
`Washington, DC. 20005-3934
`(202) 371-2600
`1330773571
`
`Atty. Dkt. No. 28440170004
`
`