Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`REMARKS
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`Favorable reconsideration of this Application,
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`in light of the following discussion,
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`is
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`respectfully requested. Claims 1-6 and 8 were previously presented. Claims 1-6 and 8 have been
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`amended. Claim 7 was previously canceled. Accordingly, claims 1-6 and 8 are pending and under
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`examination in the present Application. Applicant submits that upon entry of the present Response,
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`claims 1-6 and 8 are in condition for allowance. Moreover, the Applicant submits that no new
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`matter has been introduced by the foregoing amendments.
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`Objections to the Specification
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`In the outstanding Office Action, the title was objected to because of informalities.
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`In response to the objections, the title is amended to correct the noted informalities.
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`In
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`light of their formal nature, the changes to the title do not raise a question of new matter.
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`Rejections under 35 U.S.C. §103
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`In the outstanding Office Action, claims 1-6 and 8 are rejected under 35 U.S.C. 103 as
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`being unpatentable over Ryu (KR 101817064) in further in view of Hayashi (Japanese Patent No.
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`2011042976)
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`Addressing now the rejection of claims 1-6 and 8 under 35 U.S.C. § 103 as being
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`unpatentable by Ryu and Hayashi, this rejection is respectfully traversed. Claim 1, from which the
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`other pending claims depend, is the independent claim presently under consideration. Claim 1 has
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`been amended to overcome the rejection under 35 U.S.C. § 103. For ease of reference, claim 1
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`now recites:
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`A retaining mechanism for teeth, comprising:
`a tooth point having a coupling space that comprisesa first
`space and a second space communicating with each other;
`a damper structure accommodated in the first space, and
`comprising a flexible portion having an insertion groove whichis
`positioned on one surface thereof and a hollow therein extending
`from the one surface to another surface opposite to the one surface
`and having one side which is open, a hard portion inserted in the
`insertion groove and having one surface whichis a flat surface and
`is exposedto an outside, and a sealing portion blocking the opened
`side of the hollow; and
`a coupling unit accommodated in the second space, a
`portion of which is in contact with the one surface of the hard
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`portion_in an initial state, in which the coupling unit is inserted into
`the second space,
`wherein the sealing portion is an element separated from the
`tooth point,
`wherein coupling of the flexible portion and the sealing
`portion is made in fitting operation using a protrusion,
`wherein, in responseto rotation of the coupling unit in the
`second space from the initial state, another portion different from
`the portion of the coupling unit comes into contact with the hard
`portion,
`wherein when the coupling unit rotates in one direction
`from the initial state,
`to become a first rotation state, a portion
`where the coupling unit and the hard portion contact each otheris
`movedin a direction toward the flexible portion further than the
`initial state, and thus, the hard portion is moved in the direction
`toward the flexible portion further than the initial state, and
`wherein the flexible portion is compressed and deformed
`between the hard portion and an inner surface of the tooth point
`forming the first space.
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`Non-limiting support for the amendment may be found, for example, at Figs. 2-4, and
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`paragraph [0054] of Applicant’s published specification.
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`1) Features of Claimed Invention
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`|H111 H111 LILI)mesWAYILILI)LLLWeWULET
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`As amended, the independent claim now defines:
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`Y the sealing portion is an element separated from the tooth point
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`¥ coupling of the flexible portion and the sealing portion is madein fitting operation
`using a protrusion
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`2) Distinctions from Cited References
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`— YF
`-Ryu
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`(FIG. 2 of Ryu)
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`Referring to the above figure, Ryu comprises a fixing pin (3) havinga first surface portion
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`(331), a second surface portion (332), and a stopper portion (333) formed between the first surface
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`portion (331) and the second surface portion (332). Locking rubber (4) whose compression state
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`changes according to the rotational motion of the fixing pin (3) to control the combinedstate of
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`the tooth adapter (1) and the tooth point (2).
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`The locking rubber (4) includes the body portion (41) corresponding to the face portion
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`(33) of the fixing pin (3) and the rear end of the body portion (41) is inserted into the receiving
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`groove (215) to secure the body portion (41). It is provided with a rubberpart (42) that is elastically
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`deformed by the pressure of the body portion (41).
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`However, Ryu's rubber part (42) does not have any hollow inside, and therefore does
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`not have any sealing part to block the hollow.
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`Thus, Ryu fails to teach or suggest the claim features.
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`- Hayashi
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`te
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`(FIG. 1 of Hayashi)
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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` 5
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`3
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`x
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`(FIG. 2 of Hayashi)
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`Referring to the above figures, Hayashi's piece member (7) has a piece member body (9)
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`madeofan elastic resin material and a left spring member (10) located on the piece member body
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`(9).
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`Hayashiarguablyhasabufferinghole(13)thepiecememberbody(9),butdoesinside
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`nothaveanyseparatesealingparttoblocktheopenpartofthebufferinghole(13).
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`10
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`
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`(FIG. 5 of Hayashi)
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`Therefore, when the piece member(7) is inserted into the corresponding part of the tooth
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`member (3) and combined with the tooth member (3), Hayashi's buffering hole (13)
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`is not a
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`completely separate part from the tooth member (3), but blocked by the part that is in contact with
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`the buffering hole (13)
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`(for example,
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`the engaging
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`convex portion (5)
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`in FIG.
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`1 and the tooth
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`member (3) in FIG. 5).
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`Thus, since Hayashi's
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`piece member (7) does not have any
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`sealing
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`part to block the open
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`portion of the buffering hole (13), it is blocked by the portion of the tooth member (3) that is in
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`contact with the buffering hole C13).
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`Under the Hayashi’s arrangements, the tooth member (3) or the engaging convex portion
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`(5) cannot accurately block the open buffering hole (13), and the buffering hole (13) of which the
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`parts opened due to the mounting state of the piece member (7) can be broken or damaged.
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`However, the claimed invention provides the sealing portion (12) which is a completely
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`separate part from the engaging convex portion of the tooth member and the adapter member, and
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`this sealing portion (12) is, by using a protrusion and using a custom fitting method, combined
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`with the flexible portion (11). However, Hayashifails to teach or suggest those claim mechanisms.
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`11
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`Further, Applicant noted that in the previous response, the following amendmentof claim
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`1 was missed.
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`a coupling unit accommodated in the second space, a portion of which
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`is in contact with the one surface of the hard portion_in_an initial state,
`in
`which the coupling unit is inserted into the second space,
`...” (Marked-up added).
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`Non-limiting support for the amendment may be found, for example, at original claim 7
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`and paragraphs [0045]-[0050] and [0119]-[0123], Figs. 3 and 4 of Applicant’s published
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`specification.
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`For the Office’s convenience, Applicant respectfully presents again the arguments below
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`whichare the same or similar to those in the previous response, and Applicant respectfully request
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`the Office’s reconsideration of the arguments along with the claim amendment.
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`(Fig. 3 of Present Application)
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`H111
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`H111
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`H111
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`SS11
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`(Fig. 4 of Present Application)
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`Referring to the above figures, the claimed invention, as amended, defines:
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`¥ a damperstructure accommodatedin the first space, and comprising a flexible portion
`(11) having an insertion groove (H112) which is positioned on one surface thereof and
`a hollow (H111) therein extending from the one surface to another surface opposite to
`the one surface and having one side which is open, a hard portion (13) inserted in the
`insertion groove and having one surface whichis a flat surface and is exposed to an
`outside, and a sealing portion (12) blocking the openedside of the hollow (Feature 1);
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`¥ acoupling unit accommodated in the second space, a portion of which is in contact with
`one surface of the hard portion (13) in an initial state, in which the coupling unit is
`inserted into the second space (Feature 2); and
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`v wherein, in responseto rotation of the coupling unit in the second space from theinitial
`state, another portion different from the portion of the coupling unit comesinto contact
`with the hard portion (13) (Feature 3).
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`Distinct features from Cited References
`- Ryu
`
` f1:44,12,13]
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`f2:21, 22]
`P21: 212, 213, 214, 215]
`£3231, 32, 33,34]
`(33-334, 332, 333]
`
`.
`32°
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`Referring to the above figure, Ryu comprises a fixing pin (3) havingafirst surface portion
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`(331), a secondsurface portion (332), and a stopper portion (333) formed betweenthe first surface
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`(FIG. 2 of Ryu)
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`15
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`portion (331) and the second surface portion (332), and a locking rubber (4) that changes the
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`compression state according to the rotation of the fixing pin (3) and controls the combinedstate of
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`the tooth adapter (1) and the tooth point (2).
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`The locking rubber (4) comprises the body portion (41) corresponding to the face portion
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`(33) of the fixing pin (4) and the rubber portion (42) which is formed to contact the rear end of the
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`body portion (41), is inserted into the receiving groove (215), and is elastically deformed according
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`to pressure of the body portion (41).
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`However, Ryu's rubber portion (42) does not include any hollow inside. Further, the body
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`portion (41) does not protrude outward from the rubber portion (42), so the front of the body
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`portion (41) is located on an imaginary line passing throughthe front of the rubber portion (42).
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`Therefore, Ryu's rubber portion (42) does not teach or suggest the claim features of the
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`flexible
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`portion (11) having an insertion groove
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`(H112)
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`located on one side and a hollow
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`(H111) that is open on one side and extends from the inside to the other side located_on the
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`opposite side of the one side.
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`Therefore, in the claimed invention, when a physical force is applied to the hard portion (13)
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`by the coupling unit (30) through the hollow (H111) located in the flexible portion (11) and
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`deformation of the flexible portion (11) occurs, the stress generated in the flexible portion (11)
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`escapes into the hollow (H111), resulting in the effect of allowing the flexible portion (11) to be
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`more easily deformed due to the rotational motion of the coupling unit (30).
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`However,there are no holes in the rubber portion (42) of Ryu, and becauseofthis, the rubber
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`portion (42) of Ryu has a completely different structure from the flexible portion (11) of the present
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`invention, and the effect by the hollow (H111) also cannotbe achieved by Ryuatall.
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`Since the rubber portion (42) of the Ryu does not have a hole therein, Ryu does not have
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`any structure to block any hole. Therefore, Ryu fails to teach or suggest the claimed features
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`of the sealing portion (12).
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`In addition, the body portion (41) located in the rubber portion (42) of Ryu has no part that
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`protrudes outward from the rubber portion (42). Also, as shown in Figure 5, the side of the body
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`portion (41) is attached to the rubber portion (42). Therefore, when the body portion (41) is
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`compressed by the rotational action of the fixing pin (3), the compression action is not easily
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`performed by the side portion attached to the rubber portion (42), and rotating the fixing pin (3)
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`may cause inconvenienceto the user.
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`32-5
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`32...
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`f LF]
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`f Ct Y
`
`A
`
`a
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`(Fig. 5 of Ryu)
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`17
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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`However,the hard portion (13) of the present invention partially protrudes from the inserted
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`flexible portion (11), so that it is free and not attached to the side portion of the protruding flexible
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`portion (11). Therefore, when pressure is applied toward the hard portion (13) by the rotational
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`movementof the coupling unit (30), the protruding portion of the hard portion (13), which is ina
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`free state, is compressed so that the user can more easily manipulate the coupling unit (30).
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`Thus, Ryu's rubber part (42) has a structure different from the flexible portion (11) of the
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`present invention, which has a hollow (H1I11), and Ryu’s body part (41) also has a different
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`structure from the claimed hard portion (13) since the body part (41) does not have a protruding
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`part protruding to the outside.
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`Additionally, Ryu does not teach or suggest at all the sealing portion (12) that blocks the
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`hollow (H111) located inside the flexible portion (11) of the present invention.
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`- Hayashi
`
`
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`fa
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`(Fig 1 of Hayashi)
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`18
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
`
`#
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`"Syheernees Me,
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`(Fig 2 of Hayashi)
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`Referring to the abovefigures, Hayashi discloses a piece member(7) having a piece member
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`body (9) made of an elastic resin material and a left spring member (10) located on the piece
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`member body (9).
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`Here, the exposed part of the piece member body (9) has an uneven surface rather than a
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`flat surface, and the left spring member(10) is located to surround the exposed uneven surface of
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`the piece member body (9).
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`In addition, Hayashi has a buffering hole (13) inside the piece member body (9), but does
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`not have a separate sealing part to block the open portion of the buffering hole (13).
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`Therefore, under Hayashi’s arrangements, when pressure is applied to the piece member
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`body (9) due to the insertion action of the locking member (8) and a change in the shape of the
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`buffering hole (13) occurs, the shape and position of the piece member body (9) maybedistorted.
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`This may cause damageto the piece member body (9).
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`19
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`However, the present invention is provided with a separate sealing portion (12) that blocks
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`the hollow (H111), and the shape and position of the flexible portion (11) with the hollow (H111)
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`insideis firmly maintained, thereby forming a damperstructure of whichthelifespan also increases.
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`Additionally, referring now to below Fig. 5 of Hayashi, the locking member (8) is inserted
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`into the through-hole (6a) between the adapter member (2) and the piece member(7) through the
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`insertion action of the locking member (8) moving inastraight direction (e.g., left and right
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`direction) to perform the coupling operation.
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`In other words, unlike the present invention, Hayachi uses a linear motion rather than a
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`rotational motion of the locking member(8) for the coupling operation.
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`
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`(Fig 5 of Hayashi)
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`Therefore, it is advantageousfor the exposed surface of the piece member body (9) to have
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`an uneven surface rather than a flat surface for the coupling of the locking member(8) by the
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`linear movement of the locking member(8).
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`In addition, due to the repetitive linear motion of the locking member(8), the piece member
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`body (9) made of an elastic resin material is at risk of damage such as wear dueto the repeated
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`insertion and removal of the locking member (8). Therefore, the left spring member (10) made
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`of metal surrounds the uneven surface of the piece member body (9) performs the function of
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`20
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`

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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`preventing damage to the uneven surface of the piece member body (9) by the locking member
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`(8).
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`Therefore, the left spring member (10) is not intended to perform the role of the rigid part
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`(13) of the present invention, but performs a protective function to protect the uneven surface of
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`the piece member body (9) that protrudes outward.
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`Accordingly, Hayashi's left spring member (10) is a different component with a different
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`function and purpose than the claimed hard portion (13) which is brought out to the outside and
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`changes the pressure applied to the flexible portion (11) according to the rotational motion of the
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`coupling unit (30) to control the coupling operation of the coupling unit (3).
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`Additionally, in Hayashi, when the locking member(8) is not inserted between the through-
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`holes (6a), the locking member (8) maintains a non-contact state with the left spring member (10),
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`so the initial state of the locking member (8) is in a non-contact state with the left spring member
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`(10).
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`As such, Hayashi is not equipped with the sealing portion (12) of the present invention at
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`all, and the operating state of the locking member (8) is completely different from that of the
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`coupling unit (30) of the present invention, so the Features 1-3 of the present invention is not
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`disclosed by the cited references.
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`Thus, Applicant respectfully submits that Ryu and Hayashi, even if considered in
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`combination, fail to teach or suggest each and every element of independent claim 1 of the present
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`application.
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`As aresult, Applicant respectfully submits that independentclaim 1 is patentable over Ryu
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`and Hayashi. As claims 2-6 and 8 depend from independent claim 1, Applicant respectfully
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`submits that claims 2-6 and 8 are likewise patentable over the cited references.
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`Accordingly, for at least the reasons set forth above, Applicant respectfully requests that
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`the §103 rejections of claims 1-6 and 8 be withdrawn.
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`21
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`Appl. No.: 17/396,113
`Reply to Office Action of November 13, 2023
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`Conclusion
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`Accordingly, reconsideration of the outstanding Office Action and allowanceof the present
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`application and all the claims therein are respectfully requested.
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`It is submitted that all of the pending issues have been addressed. However, the absence
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`of a reply to a specific rejection, issue or comment does not signify agreement with or concession
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`of that rejection, issue or comment.
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`In addition, because the arguments made above may not be
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`exhaustive, there may be reasons for patentability of any or all pending claims (or other claims)
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`that have not been expressed. Finally, nothing in this reply should be construed as an intention to
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`concede any issue with regard to any claim, except as specifically stated in this reply, and the
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`amendment of any claim does not necessarily signify concession of unpatentability of the claim
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`prior to its amendment. Accordingly, entry of the amendments and allowance of the claims are
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`respectfully requested.
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`Should the Examiner have any questions or comments regarding this matter,
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`the
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`undersigned may be contacted at the below-listed telephone number.
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`Respectfully submitted,
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`‘Jae Youn Kim/
`Jae Youn Kim, Reg. No. 69,215
`Byungwoong Park, Reg. No. 80,134
`
`Date: Feb. 12, 2024
`
`Novick, Kim & Lee, PLLC
`3251 Blenheim Blvd, Suite 500
`Fairfax, VA 22030
`Telephone 703-745-5495
`Facsimile 703-563-9748
`E-Mail docketO! @nkllaw.com
`
`PK5914918.A02; SK/bwp
`
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