REMARKS
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`At the outset, the Examiner is thanked for the review and consideration. The Office
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`Action has been received andits contents reviewed.
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`The above amendments are made in response to the Office Action. Applicant does not
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`concede that the rejections are proper. However, the amendments are made to expedite the
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`prosecution of the instant application. Applicant reserves the right to pursue the original claims
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`in this and in any other applications. The Examiner’s reconsideration is respectfully requested
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`in view of the above amendments andthe following remarks.
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`Claims 13 and 14 are amended, claims 15 and 22 are canceled, and claims 24-25 are
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`newly added by this submission. Support for the amendments and new claim can be found at
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`least at the claims, Specification and figures as originally filed. The present amendment
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`introduces no new matter, as support is found throughout the originally filed Specification,
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`figures and claims as noted. Applicant further notes that any referenceto the figures is by way
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`of illustration only and is not intended to limit the scope of the claims to any particular
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`embodiment.
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`Claims 1-14, 16-21, and 23-25 will be pending in the present application.
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`Claims 1, 5, 13, and 14 will be independent upon entry of this amendment.
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`Allowable Subject Matter
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`Applicant deeply appreciates the indication of allowable subject matter in
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`claims 1-12 and 19.
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`Rejections of Claims under 35 U.S.C. §§ 102-103
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`Claims 13, 15, 16, and 21-23 are rejected under 35 U.S.C. § 102(a)(1) as being
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`anticipated by Park (US 2019/0115400); Claim 14 is rejected under 35 U.S.C. § 103 over Park
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`‘400 in view of Choi (US 2009/0315451); Claim 17 is reyected under 35 U.S.C. § 103 over Park
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`‘400 in view of Oh (US 2018/0321764); and Claims 18 and 20 are rejected under 35 U.S.C. §
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`Atty Docket No. SD-T21065-YPB
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`103 over Park ‘400 and Ohand further in view of Park (US 2013/0242372). Reconsideration
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`is respectfully requested.
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`“A claim is anticipated only if each and every elementas set forth in the claim is found,
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`either expressly or inherently described, in a single prior art reference.” Verdegaal Bros. v.
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`Union Oil Co. of California, 814 F.2d 628, 631, 2 USPQ2d 1051, 1053 (Fed. Cir. 1987).
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`Additionally, the prior art reference must clearly and unequivocally disclose the claimed
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`invention or direct those skilled in the art to the invention without any need for picking,
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`choosing, and combining various disclosures not directly related to each other by the teachings
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`of the cited reference. [n re Arkley, 455 F.2d 586, 587 (CCPA 1972).
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`Dependent claim 22: Dependent claim 22 recites:
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`“The display apparatus of claim 13, wherein
`the pad being electrically connected to connection wiring underneath
`the pad, and
`a data line is connected to the connection wiring to transmit data signals
`to pixels within the display area from the pad.”
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`The Office Action (page 4) addresses this limitation byreciting:
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`“TRe claim 22] PARK also discloses the display apparatus wherein the
`pad being electrically connected to connection wiring underneath the pad, and a
`data line is connected to the connection wiring to transmit data signals to pixels
`within the display area from the pad (see paragraph [0091 ]-[0093]).”
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`Applicant respectfully disagrees. Applicant has reproduced FIG. 1 of Park ‘400 below
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`for ease of discussion:
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`Atty Docket No. SD-T21065-YPB
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`8
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`
`
`area
`
`po
`
`,
`(
`(i
`POLPakPICPARPSR
`.
`= pp
`Se
`
`
`A
`first pad group
`~ itis this pad
`group that is
`connected to
`data lines 171
`
`m
`pad portion
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`“=.second pad
`group -- this
`correspondsto
`FIGS. 3 & 4 of
`Park and is
`relied upon in
`the rejection
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`Atty Docket No. SD-T21065-YPB
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`9
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`display
`DA"area
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`
`
`, iBAosebending
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`
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`Applicant submits that in the rejection of base claim 13, the Office Action previously
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`relied on FIG. 3 and paragraphs 0074 to 0076 of Park ‘400. Applicant submits that these
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`sections of Park ‘400 pertain to second pad group PZR (not to be confused with second pad P2).
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`Applicant subrnits that the structures of Park ‘400 relied upon in the rejection for a disclosure
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`of Applicant's claimed pads are and cannot be electrically connected to a data line because Park
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`‘400 teaches that it is the first pad group PiC (not to be confused with first pad Pt) that is
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`connected to data line 171 (see paragraphs 0056 and 0093 ofPark ‘400 for example). Because
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`the Office Action relies on second pad group P2R to reject Applicant’s claims, and because the
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`data lines 171 of Park ‘400 are connected to the first pad group PIC and not the second pad
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`group P2R, Applicant submits that Park ‘400fatis to anticipate or render obvious Applicant’s
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`dependent claim 22. Therefore, Applicant has arnended base claim 13 according to dependent
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`claim 22 by this amendment.
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`Thus, independent claim 13 is directed to patentable subject matter, and the dependent
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`claims are similarly directed to patentable subject matter by virtue of their dependency as well
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`as for the additional features recited. Accordingly, withdrawal of the rejection is respectfully
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`requested.
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`Dependent claim 14: Dependent claim 14recites:
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`“The display apparatus of claim 13, wherein the contact layer comprises
`indium tin oxide (ITO).”
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`The Office Action (page 5) justifies the rejection of claim 14 by reciting:
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`“TRe claim 14] PARK discloses the device as claimed and rejected in
`claim 13, but PARK does not disclose the device wherein the contact layer
`comprises indium tin oxide (ITO). CHOI discloses the device wherein the
`contact layer (81) comprises indium tin oxide (ITO) (see paragraph [0051]-
`[0052], [0080]). It would have been obvious to one ordinary skill in the art prior
`to the effective filling date of the instant application wherein the contact layer
`comprises indium tin oxide (ITO) in the device of PARK in order to improve the
`interface characteristic.”
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`Applicant respectfully disagrees. Applicant submits that Applicant’s claimed contact
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`layer C-PADis formed bya different process than the formation of Applicant’s claimed pixel
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`electrode. In contrast, Applicant submits that the above cited paragraphs of Choi teach that the
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`Atty Docket No. SD-T21065-YPB
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`cited contact assistant 81 is formed by the same process as that of the pixel electrode 191.
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`Therefore, Applicant submits that the structure of Choi does not disclose, teach, suggest, or
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`render obvious Applicant’s claimed contact
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`layer C-PAD comprised of ITO.
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`Because
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`Applicant’s claim 14 is not fairly rendered obvious in view of the Park / Choi applied art
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`combination, Apphecant has placed claim 14 into independent form by this amendment.
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`Newly Added Claims
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`Applicant has also added new claims 24-25, each of which include no new matter and
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`is fully supported by the specification and the drawings of the present application. Each new
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`claim further defines the distinct subject matters of the present application. Each new claim has
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`been carefully written to avoid any questions under 35 U.S.C. § 112. Accordingly,it is believed
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`that each new claim is in condition for allowance.
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`Conclusion
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`In view of the foregoing, it is respectfully submitted that the instant application is in
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`condition for allowance. Accordingly, it is respectfully requested that this application be
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`allowed and a Notice of Allowance issued.
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`If the Examinerbelieves that a telephone conference with Applicant’s attorneys would
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`be advantageousto the disposition of this case, the Examineris cordially requested to telephone
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`the undersigned.
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`Atty Docket No. SD-T21065-YPB
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`ll
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`In the event the Commissioner of Patents and Trademarks deems additional fees to be
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`due in connection with this application, Applicant’s attorney hereby authorizes that such fee be
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`charged to Deposit Account No. 50-5622.
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`Date: November 25, 2024
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`Respectfully submitted,
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`By: /Matthew Lestina/
`Matthew Lestina
`USPTO Reg. No.: 44,437
`Jae Y. Park /Jae Y. Park/
`USPTO Reg. No.: 62,629
`Customer No. 82,727
`Attorneys for Applicant(s)
`Kile Park Reed & Houtteman PLLC
`1101 30th Street NW
`Suite 500
`Washington, DC 20007
`Tel. No.: 202-897-4761
`Fax No.: 202-670-5937
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`Atty Docket No. SD-T21065-YPB
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