Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`REMARKS
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`Claims 1, 4, 5, 7, 9, 10, and 16 have been amended, and claims 2, 3, and 8 have been
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`canceled without prejudice or disclaimer. Accordingly, claims 1, 4-7, and 9-20 are currently
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`pending in the Application, of which claims 1, 10, and 16 are independent.
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`Applicant respectfully submits 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 the Figures and original claims 2, 3, 8, 10 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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`Rejections under 35 us. C. § 102
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`Claims 1 and 2 stand rejected under 35 U.S.C. § 102(a)(1) as allegedly being
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`anticipated by US. Patent Application Publication No. 2014/0132534 applied for by Kim (“Kim”).
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`Applicant respectfully traverse this rejection for at least the following reasons.
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`In order for a rejection under 35 U.S.C. § 102(a)(1) to be proper, a single reference must
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`disclose every claimed feature. To be patentable, a claim need only recite a single novel
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`feature that is not disclosed in the cited reference. Thus, the failure of a cited reference to
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`disclose one or more claimed features renders the 35 U.S.C. § 102(a)(1) rejection improper.
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`Without conceding to the correctness of the Examiner’s rejection but to advance
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`prosecution, claim 1 has been amended to recite elements of claim 3, which are admittedly not
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`anticipated by Kim. Claim 2 is canceled without prejudice or disclaimer, rendering its rejection
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`moot.
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`

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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 102(a)(2)
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`rejection of claim 1.
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`Rejections Under 35 U.S. C. § 103
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`Claims 3-12, 14, 15, 19, and 20 stand rejected under 35 U.S.C. § 103 as allegedly being
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`unpatentable over Kim. Applicant respectfully traverses this rejection 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 USPQZd 1438 (Fed. Cir. 1991).
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`Claim 1
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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`As claims 3 and 8 have been canceled without prejudice or disclaimer and included in
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`amended claim 1, amended claim 1 will be addressed herein.
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`The Office Action fails to establish a prima facie case of obviousness of amended claim
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`1 at least because even if modified as suggested, Kim fails to disclose or suggest every claimed
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`feature.
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`Claim 1, sans amendment, recites, inter alia, “a circuit layer disposed on the base film,
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`the circuit layer comprising a plurality of gate lines, a plurality of data lines, a sense driving unit,
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`and a gate driving unit.” Thus, the gate lines, the data lines, the sense driving unit, and the gate
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`driving unit” are all comprised in a circuit layer. As amended, claim 1 further recites, inter alia,
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`that “the gate driving unit comprises a plurality of gate stages, and the sense driving unit” that
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`comprises the driving electrodes and the sensing electrodes also “comprises a plurality of sense
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`stages, wherein the plurality of gate stages and the plurality of sense stages are arranged
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`in the same layer” (emphasis added). The Office Action alleges that these elements are
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`disclosed by Kim. Office Action, pages 2 and 3. Applicant respectfully disagrees.
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`In rejecting claim 1, the Office Action alleges that IC 200 discloses the claimed gate
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`driver.
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`ld., page 3. However, Kim’s paragraph [0071] merely discloses that “IC 200 may further
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`comprise a gate driver...” With respect to prior claim 2, the Office Action cites to “the touch
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`driving electrodes 110” and paragraph [0064] of Kim to allege that “the plurality of gate stages
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`and the plurality of sense stages are arranged in the same layer.” However, nothing in Kim
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`discloses or suggests that the IC 200 Kim containing the “the sense driving unit” that comprises
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`the driving electrodes and the sensing electrodes and “the plurality of gate stages and the
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`plurality of sense stages are arranged in the same layer.” Id. Indeed, as the driving and sensing
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`electrodes are not part of the IC 200, it is unclear how they could be “arranged in the same layer
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`or the same circuit layer.
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`10
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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`In rejecting claim 3, the elements of which are now recited in claim 1, the Office Action
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`cites to the single “sync signal generator 220” to somehow allege a “first sync signal and a
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`second sync signal” that “are interpreted as a first clock signal and a second clock signal.” ld.,
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`page 4 (emphasis added). However, Applicant has separately claimed the first clock signal, the
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`second clock signal, and the frame start signal, such that it is legal error to read a single sync
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`signal generator onto the separately-recited first clock signal and second clock signal.
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`The Office Action further admits that “Kim does not expressly teach a frame start signal
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`wherein a first gate stage among the plurality of gate stages receives the frame start signal.” ld.
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`to allegedly cure this deficiency, the Office Action alleges “it is an obvious design choice for
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`Kim's display device to have a frame start signal wherein a first gate stage among the plurality
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`of gate stages receives the frame start signal since Kim's one frame can be divided into a
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`display period and a touch period.” ld., pages 4 and 5. However, Kim does not even disclose
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`that the gate driver has a plurality of stages, let alone any details of the gate driver.
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`With respect to prior claim 8, now incorporated into amended claim 1, the Office Action
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`cites to FIGS. 2 and 3 and paragraph [0094] of Kim to allege that Kim teaches “the plurality of
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`gate stages and the plurality of sense stages are electrically connected.” ld., page 6. Again,
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`Applicant respectfully submits that Kim fails to disclose or suggest a plurality of gate stages,
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`such that the mere disclosure that driving IC 200 and touch IC 300 may be connected, such as
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`by flexible printed circuit (FPC) 400, is insufficient to disclose or suggest at least this element
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`recited in amended claim 1.
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`Claim 10
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`Claim 10 is amended into independent form. Amended claim 10 recites, inter alia, “a
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`circuit layer disposed on the base film, the circuit layer comprising a plurality of gate lines, a
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`plurality of data lines, a sense driving unit, and a gate driving unit.” Thus, the gate lines, the data
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`lines, the sense driving unit, and the gate driving unit” are all comprised in a circuit layer. As
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`11
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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`amended, claim 10 further recites, inter alia, that “the gate driving unit comprises a plurality of
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`gate stages, and the sense driving unit” that comprises the driving electrodes and the sensing
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`electrodes also “comprises a plurality of sense stages, wherein the plurality of gate stages
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`and the plurality of sense stages are arranged in the same layer” (emphasis added). The
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`Office Action alleges that these elements are disclosed by Kim. Office Action, pages 2 and 3.
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`Applicant respectfully disagrees.
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`The Office Action alleges that IC 200 discloses the claimed gate driver.
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`ld., page 3.
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`However, Kim’s paragraph [0071] merely discloses that “IC 200 may further comprise a gate
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`driver...” With respect to the elements of prior claim 2, the Office Action cites to “the touch
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`driving electrodes 110” and paragraph [0064] of Kim to allege that “the plurality of gate stages
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`and the plurality of sense stages are arranged in the same layer.” However, nothing in Kim
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`discloses or suggests that the IC 200 Kim containing the “the sense driving unit” that comprises
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`the driving electrodes and the sensing electrodes and “the plurality of gate stages and the
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`plurality of sense stages are arranged in the same layer.” Id. Indeed, as the driving and sensing
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`electrodes are not part of the IC 200, it is unclear how they could be “arranged in the same layer
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`or the same circuit layer.
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`With respect to claim 10, the Office Action cites to the single “sync signal generator 220”
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`to somehow allege a “first sync signal and a second sync signal” that “are interpreted as a first
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`clock signal and a second clock signal,” as well as additional clock signals. ld., page 6
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`(emphasis added). However, Applicant has separately claimed the first clock signal, the second
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`clock signal, the third clock signal, and the fourth clock signal such that it is legal error to read a
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`single sync signal generator onto the separately-recited first to fourth clock signals.
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`The Office Action further alleges “it is an obvious design choice for Kim's display device
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`to have a frame start signal, wherein the plurality of driving control signals comprise a third clock
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`signal, a fourth clock signal, and a second frame start signal different from the first frame start
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`12
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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`signal, wherein a first gate stage among the plurality of gate stages receives the first frame start
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`signal, each of the plurality of gate stages receives the first clock signal and the second clock
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`signal, a first sense stage among the plurality of sense stages receives the second frame start
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`signal.” ld., pages 6 and 7. However, Applicant respectfully submits that Kim does not even
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`disclose that the gate driver has a plurality of stages, let alone any details of the gate driver.
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`Claim 16
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`Claim 16 recites, inter alia, that “the gate driving unit comprises a plurality of gate
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`stages” and “the sense driving unit comprises a plurality of sense stages.” The Office Action
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`alleges that these elements are disclose in paragraphs [0093] and [0094] of Kim. Office Action,
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`page 8. Again, Applicant respectfully submits that Kim fails to disclose or suggest a plurality of
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`gate stages. The mere disclosure that driving IC 200 and touch IC 300 may be connected is
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`insufficient to disclose or suggest at least this element recited in amended claim 16.
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`Moreover, without conceding to the correctness of the Examiner’s rejection but to
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`advance prosecution, claim 16 has been amended to recite, inter alia, a “plurality of gate lines
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`connected to the plurality of gate stages, respectively” as well as “the sensing unit comprising a
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`plurality of driving electrodes connected to the plurality of sense stages, respectively, and
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`configured to receive a sense driving signal from the plurality of sense stages, and a plurality of
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`sensing electrodes, wherein each of the plurality of gate stages and the plurality of sense stages
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`are configured to have a dependent connection relationship to operate in response to a signal
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`output from a previous stage.” Applicant respectfully submits that these elements are also not
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`disclosed or suggested by Kim.
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`Gate stages are configurations that provide signals to the gate lines, and sense stages
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`correspond to configurations that provide signals to the sensing electrodes. Thus, the gate
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`stage does not correspond to the gate line, and the sense stage does not correspond to the
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`driving electrode. In addition, each of the gate stages and the sense stages has a dependent
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`13
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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 2019
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`connection relationship to operate in response to a signal output from a previous stage, which is
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`not disclosed or fairly suggested by the asserted art..
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
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`of claims 1, 10, and 16. Claims 4-7, 9, 11, 12, 14, 15, and 17-20 depend from claim 1, 10, or
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`16, and are allowable at least for this reason. Since none of the alleged prior art of record,
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`whether taken alone or in any combination, discloses or suggests all the features of the claimed
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`subject matter, Applicant respectfully submits that independent claims 1, 10, and 16, and all the
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`claims that depend therefrom, are allowable.
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`Claim 13 stands rejected under 35 U.S.C. § 103 as allegedly being unpatentable over
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`Kim in view of US. Patent Application Publication No. 2016/0260385 applied for by Kawano
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`(“Kawano”). Applicant respectfully traverses this rejection for at least the following reasons.
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`Applicant respectfully submit that claim 10 is allowable over Kim, and Kawano fails to
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`cure the deficiencies of Kim noted above with regard to claim 10. Hence, claim 13 is allowable
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`at least because it depends from an allowable claim 10.
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
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`of claim 13.
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`Other Matters
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`In addition to the amendments mentioned above, claims 4, 5, 7, and 9 have been
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`amended solely for maintaining proper dependency. These amendments are not made to avoid
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`prior art or narrow the claimed subject matter, and no change in claim scope is intended.
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`Therefore, Applicant does not intend to relinquish any subject matter by these amendments.
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`14
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`Application No.: 16/013,944
`Reply dated November 28, 2019
`Response to Office Action of September 5, 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 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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`[Christopher B. Kilnerl
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`Christopher B. Kilner
`Reg. No. 45,381
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`Date: November 28, 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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