REMARKS
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`At the outset, the Examineris thanked for the review and consideration of the pending
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`application. The Office Action has been received and its 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,
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`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 in
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`this and in any other applications. The Examiner’s reconsideration is respectfully requested in view
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`of the above amendmentsand the following remarks.
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`By this Response, claims 1, 9, and 15 are amended, and claims 6 and 14 are canceled.
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`Support for the amendments can be found throughout the claims, the specification, and the
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`drawingsas originally filed. The present amendmentintroduces no new matter, as support is found
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`throughoutthe originally filed specification, drawings and claims as noted.
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`Claims 1-5, 7-13, and 15-20 are pending in the present application upon entry of this
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`Response.
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`Claims 1 and 9 are independent.
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`Rejection of Claims under 35 U.S.C. § 103
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`Claims 1-5, 9-13, and 18-20 are rejected under 35 U.S.C. § 103 as allegedly being obvious
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`over Kim et al. (US 10,671,124) in view of Hanet al. (US 10,573,695). Claims 6-8 and 14-17 are
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`rejected under 35 U.S.C. § 103 as allegedly being obvious over Kim in view of Han, and further
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`in view of Knopp (US 2020/0087072). These rejections are respectfully traversed.
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`In order for an obviousness rejection to be proper, the Examiner must meet the burden of
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`establishing that all elements of the invention are disclosed in the prior art; that the prior art relied
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`upon, coupled with knowledge generally available in the art at the time of the invention, must
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`contain some suggestion or incentive that would have motivated the skilled artisan to modify a
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`reference or combined references; and that the proposed modification of the prior art must have
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`had a reasonable expectation of success, determined from the vantage point of the skilled artisan
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`at the time the invention was made. /n re Fine, 5 U.S.P.Q.2d 1596, 1598 (Fed. Cir. 1988); Jn re
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`Atty Docket No. SD-220119-PKD
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`6
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`
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`Wilson, 165 U.S.P.Q. 494, 496 (C.C.P.A. 1970); Amgen v. Chugai Pharmaceuticals Co., 18
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`U.S.P.Q.2d, 1016, 1023 (Fed. Cir. 1991). See MPEP§ 2143.
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`In the interest of expediting prosecution, independent claim 1 is hereby amendedtorecite,
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`inter alia, that “a surface of the rotation belt that extends to the first roller and the second roller
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`and that is parallel to the first direction is flat.” Independent claim 9, which has its own scope, now
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`recites a similar feature.
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`It is respectfully submitted that none of Kim, Han, nor Knopp disclose that “a surface of
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`the rotation belt that extends to the first roller and the secondroller and that is parallel to the first
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`direction is flat,” as now recited. Accordingly, it is respectfully submitted that the proposed
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`combinations including Kim, Han, and/or Knoppare likewise deficient, even considering the
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`knowledge of one of ordinary skill in theart.
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`At page 8, the Office Action concedes that “the combination [of Kim and Han] fails to
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`explicitly teach a flat surface of the rotation belt.” The Office Action rejects this subject matter
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`previously of dependent claim 6 nonetheless, contending that the tertiary citation to Knopp
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`providesthis disclosure at paragraph [0018]. This contention is respectfully traversed.
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`Knopp does not relate to display devices, but rather discusses conveyer belts. Knopp,
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`Abstract. It is respectfully submitted that one of ordinary skill in the art would not have been
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`motivated to consider conveyorbelts at the time of the present invention.
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`Regardless, it 1s respectfully submitted that even if Knopp is considered, the proposed
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`combination of Kim, Han, and Knoppfails to disclose the feature, as amended.
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`The citation to Knopp discusses an embodimentdisclosed in FIG.
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`1 of Knopp, which is
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`reproduced below:
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`Atty Docket No. SD-220119-PKD
`
`7
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`The Office Action contends that “Knopp teaches, wherein a surface ofthe rotation belt that
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`is parallel to the first direction is flat (Knopp paragraph [0018] discloses that the bearing side of
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`the conveyorbelt (i.e., rotation belt) is planar(i.e. flat).”
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`Atty Docket No. SD-220119-PKD
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`8
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`€
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`However, as amended, “a surface of the rotation belt that extendsto thefirst roller and the
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`secondroller and that is parallel to the first directionis flat.” This aspect is not disclosed by Knopp
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`as can be seen in FIG. 1, reproduced above. Indeed, there is no discussion in the citations to Kim,
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`Han, or Knoppofa surface of a rotation belt that extendsto a first roller and a secondroller, and
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`that is flat in such a portion. Accordingly, it is respectfully submitted that combination of Kim,
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`Han, and Knoppis likewise deficient, even considering the knowledge of one of ordinary skill in
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`the art.
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`Thus, amended independent claims 1 and 9 are directed to patentable subject matter, and
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`the dependent claims are similarly directed to patentable subject matter by virtue of their
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`dependency as well as for the additional features recited. Accordingly, favorable reconsideration
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`and withdrawalof the rejection are respectfully requested.
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`Atty Docket No. SD-220119-PKD
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`9
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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 allowed
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`and a Notice of Allowance issued.
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`If the Examiner believes that a telephone conference with Applicant’s attorneys would be
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`advantageousto the disposition of this case, the Examineris cordially requested to telephone the
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`undersigned.
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`In the event the Commissioner of Patents and Trademarks deems additional fees to be due
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`in connection with this application, Applicant’s attorney hereby authorizes that such fee be charged
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`to Deposit Account No. 50-5622.
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`Date: July 3, 2024
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`Respectfully submitted,
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`By: /Christopher P. Mitchell/
`Christopher P. Mitchell
`USPTOReg. No.: 54,946
`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.: 202 591-2413
`Fax No.: 202-670-5937
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`Atty Docket No. SD-220119-PKD
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`10
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