Application No.: 17/549 ,624
`Reply dated December 25, 2023
`Responseto Office Action of September 29, 2023
`
`REMARKS
`
`The claims have not been amended. Accordingly, claims 1-20 are currently pending in
`
`the Application, of which claim 1 is independent.
`
`In view of the following Remarks, Applicant respectfully requests reconsideration and
`
`timely withdrawal of the pending rejections for the reasons discussed below.
`
`Rejections under 35 U.S.C. § 103
`
`Claims 1, 3, 8, 9, and 18-20 were rejected under 35 U.S.C. § 103 as allegedly being
`
`unpatentable over U.S. Patent Application Publication No. 2015/0078604, applied for by Seo, et
`
`al. (“Seo”) in view of U.S. Patent Application Publication No. 2015/0034413, applied for by
`
`Uetabira (“Uetabira’). Applicant respectfully traverses this rejection for at least the following
`
`reasons.
`
`Thefollowing table lists the elements of Seo that are alleged as corresponding to the
`
`claimed elements. (See OA, p, 3).
`
`
`
`
`
`Claim 1
`Seo
`
`
`Display device
`
`Display panel 70
`
`Sound generator
`Sound element 27
`
`
`First coupling layer
`
`First cushion tape 75-1
`
`Intermediate layer
`
`Resonator 76
`
`Second coupling layer
`Second cushion tape 75-2
`
`
`
`
`Seo discloses that each of the first cushion tape 75-1 and the second cushion tape 75-2
`
`includes a groove,in which the sound element 27 and the resonator 76 are formed,
`
`respectively. (See paragraph [0096]). This is clearly shown in FIG. 1 of Seo reproduced below,
`
`--5--
`
`

`

`Application No.: 17/549 ,624
`Reply dated December 25, 2023
`Responseto Office Action of September 29, 2023
`
`whereapartial area of the first cushion tape 75-1 of Seo is interposed between the sound
`
`element 27 and the display panel 70.
`
`
`
`<FIG. 1 of Seo>
`
`Assuch, Seofails to disclose or suggest that the alleged first coupling layer 75-1 does
`
`“not overlap the sound generatorin a thicknessdirection of the display panel” as required in
`
`claim 1, becausethefirst cushion tape 75-1 of Seo overlaps the sound element 27 ina
`
`thickness direction as necessarily being positioned between the sound element 27 and the
`
`display panel 70. (Emphasis added).
`
`In addition, as clearly shown in FIG. 2 of Seo, the entire resonator 76 overlaps the sound
`
`element 27. (See also FIG. 1) . As such, Seo also fails to disclose or suggest that the alleged
`
`intermediate layer 76 does “not overlap the sound generatorin a thickness direction of the
`
`display panel’ as required in claim 1, because the resonator 76 overlaps the sound element 27
`
`in a thickness direction as necessarily being positioned below the sound element27in its
`
`entirety. (Emphasis added).
`
`At least for these reasons, Seofail to disclose or suggest“the first coupling layer and the
`
`intermediate layer do not overlap the sound generator in a thicknessdirection of the display
`
`panel’, much less in the manner claimed. Uetabira fails to cure these deficiencies.
`
`--6--
`
`

`

`Application No.: 17/549 ,624
`Reply dated December 25, 2023
`Responseto Office Action of September 29, 2023
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103
`
`rejection of claim 1. Claims 3, 8, 9 and 18-20 dependfrom claim 1 and are allowable at least for
`
`this reason. Since none of the alleged prior art of record, whether taken alone or in any
`
`combination, discloses or suggests all the features of the claimed subject matter, Applicant
`
`submits that independentclaim 1, and all the claims that depend therefrom, are allowable.
`
`Claim 2 was rejected under 35 U.S.C. § 103 as allegedly being unpatentable over Seoin
`
`view of Uetabira and further in view of U.S. Patent Application Publication No. 2018/0288202,
`
`applied for by Park, ef a/. (“Park”). Applicant respectfully traverses this rejection for at least the
`
`following reasons.
`
`Applicant respectfully submits that claim 1 is allowable over Seo and Uetabira, and Park
`
`fails to cure the deficiencies of Seo and Uetabira noted above with regard to claim 1. Hence,
`
`claim 2 is allowable at least because claim 2 depends from an allowable claim 1.
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
`
`of claim 2.
`
`Claims 4-7 were rejected under 35 U.S.C. § 103 as allegedly being unpatentable over
`
`Seoin view of Uetabira and further in view of U.S. Patent Application Publication No.
`
`2017/0242290, applied for by Jenkins, ef a/. (“Jenkins”). Applicant respectfully traverses this
`
`rejection for at least the following reasons.
`
`Applicant respectfully submits that claim 1 is allowable over Seo and Uetabira, and
`
`Jenkins fails to cure the deficiencies of Seo and Uetabira noted above with regard to claim 1.
`
`Hence, claims 4-7 are allowable at least because they depend from an allowable claim 1.
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
`
`of claims 4-7.
`
`--7--
`
`

`

`Application No.: 17/549 ,624
`Reply dated December 25, 2023
`Responseto Office Action of September 29, 2023
`
`Claim 10 was rejected under 35 U.S.C. § 103 as allegedly being unpatentable over Seo
`
`in view of Uetabira and further in view of U.S. Patent Application Publication No. 2019/0141450,
`
`applied for by Yoon, et a/. (“Yoon”). Applicant respectfully traverses this rejection for at least the
`
`following reasons.
`
`Applicant respectfully submits that claim 1 is allowable over Seo and Uetabira, and Yoon
`
`fails to cure the deficiencies of Seo and Uetabira noted above with regard to claim 1. Hence,
`
`claim 10 is allowable at least because claim 10 depends from an allowable claim 1.
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
`
`of claim 10.
`
`Claim 11 wasrejected under 35 U.S.C. § 103 as allegedly being unpatentable over Seo
`
`in view of Uetabira and further in view of U.S. Patent Application Publication No. 2020/0347200,
`
`applied for by Dehn, et al. (“Dehn”). Applicant respectfully traverses this rejection for at least
`
`the following reasons.
`
`Applicant respectfully submits that claim 1 is allowable over Seo and Uetabira, and Dehn
`
`fails to cure the deficiencies of Seo and Uetabira noted above with regard to claim 1. Hence,
`
`claim 11 is allowable at least because claim 11 depends from an allowable claim 1.
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
`
`of claim 11.
`
`Claims 12-17 were rejected under 35 U.S.C. § 103 as allegedly being unpatentable over
`
`Seoin view of Uetabira and further in view of U.S. Patent Application Publication No.
`
`2010/0219750, applied for by Hori, ef a/. (“Hori”). Applicant respectfully traverses this rejection
`
`for at least the following reasons.
`
`--8--
`
`

`

`Application No.: 17/549 ,624
`Reply dated December 25, 2023
`Responseto Office Action of September 29, 2023
`
`Applicant respectfully submits that claim 1 is allowable over Seo and Uetabira, and Hori
`
`fails to cure the deficiencies of Seo and Uetabira noted above with regard to claim 1. Hence,
`
`claims 12-17 are allowable at least because they depend from an allowable claim 1.
`
`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
`
`of claims 12-17.
`
`--9.-
`
`

`

`Application No.: 17/549 ,624
`Reply dated December 25, 2023
`Responseto Office Action of September 29, 2023
`
`CONCLUSION
`
`A full and complete response has been made to the pending Office Action, and all of the
`
`groundsfor rejection have been overcome or rendered moot. Accordingly, all pending claims
`
`are allowable, and the Application is in condition for allowance.
`
`The Examiner is invited to contact Applicant’s undersigned representative at the number
`
`below if it would expedite prosecution. Prompt and favorable consideration of this Reply is
`
`respectfully requested.
`
`Respectfully submitted,
`
`!Jae Hoon Kim/
`
`Jae Hoon Kim
`Reg. No. 77,622
`
`Date: December 25, 2023
`
`CUSTOMER NUMBER: 58027
`H.C. Park & Associates, PLC
`1894 Preston White Drive
`Reston, VA 20191
`Tel: 703-288-5105
`Fax: 703-288-5139
`HCP/JHK/yem
`
`--10--
`
`

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