Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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`REMARKS
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`Claims 1, 7, and 16 have been amended. Claims 1-22 are currently pending in the
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`Application, of which claims 1 and 7 are independent.
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`Support for the amendments may be found at least in FIGS. 3 and 5 and at relevant
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`pages of the specification. No new matter is introduced.
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`Applicant respectfully requests reconsideration and timely withdrawal of the pending
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`objections and rejections for at least the reasons discussed below.
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`Rejections under 35 U. S. C. § 103
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`Claims 1-3, 6-8, and 20 stand rejected under 35 U.S.C. § 103 as being allegedly
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`unpatentable over US. Patent Application Publication No. 2016/0366379 applied for by Hickl et
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`al. (“Hickl”) in view of US. Patent Application Publication No. 2016/0178940 applied for by Yuan
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`et al. (“Yuan”). Applicant respectfully traverses this rejection for at least the following 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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`

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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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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 USPQ2d 1438 (Fed. Cir. 1991).
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`A.
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`Claim 1
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`Claim 1 recites, inter alia:
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`a plurality of display modules, each of the display modules
`comprising:
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`a display area comprising:
`a first sub-area comprising at least one first pixel unit; and
`at least one second sub-area disposed to adjoin and to
`surround the first sub-area, the at least one second sub-area
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`comprising at least one second pixel unit; and
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`wherein each of the at least one first pixel unit and the at least one
`second pixel unit comprises:
`a first pixel configured to display a first color;
`a second pixel configured to display a second color; and
`a third pixel configured to display a third colors, the first, second,
`and third colors being different from each another, and
`wherein the at least one second pixel unit further comprises:
`at least one fourth pixel configured to display a white color.
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`(Emphasis added). The Office Action alleges that Hickl discloses the first sub-area and
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`at least one second sub-area of claim 1, and that since the fourth sub-pixel W of Yuan discloses
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`the fourth pixel configured to display a white color, Hickl in view of Yuan discloses the above
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`features of claim 1. Office Action, at 5-7. Particularly, The Office Action alleges that since
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`“Yuan teaches .
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`.
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`. a plurality of pixels .
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`.
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`. [comprising] three color pixels and a white color
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`pixel,” it would have been obvious to .
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`.
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`. [modify] the video wall-type display device of Hickl to
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`have the second pixel to comprise at least one fourth pixel configured to display a white color,
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`as taught by Yuan, in order to improve quality of the color filter substrate and enhance visual
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`

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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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`effects of the display device.” Id., at 4. Applicant respectfully disagrees, and respectfully
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`submits that Office Action fails to establish a prima facie case of obviousness of claim 1 at least
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`because the Office Action fails to provide a persuasive reason to combine Hickl and Yuan in the
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`manner claimed.
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`Hickl specifically provides that the embodiments of the invention provides reduced
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`impact on the inter-tile seams from thermal and humidity expansion and relative movement.
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`Particularly, paragraphs [0028] and [0029] of Hickl provides that:
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`[0028] An advantage of some embodiments is that the impact of thermal and
`humidity expansion and the relative movement of tiles with respect to each
`other on the inter-tile seams can be reduced. This allows the use of thin brittle
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`substrates and reduces weight of components.
`[0029] An advantage of some embodiments is that the installation effort can be
`reduced. An advantage of some embodiments is that projectors require less
`readjustment if environmental conditions are changing.
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`(Emphasis added). Overall, Hickl merely discloses the correlation between the
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`distances and coefficients of thermal expansion in connection with the first substrate 1, the
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`polymer layer 3, the second substrate 2, and the second layer 6 of the seamless tiled display.
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`See id., FIGS. 3, 4A, 4B, 5, 8, 9, and 11. None of the embodiments illustrate a feature
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`connected to improving the optical characteristic of the seamless tiled display.
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`On the other hand, Yuan discloses that embodiments of the color filter substrate are
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`configured to optically compensate for the peripheral display region being partially covered by
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`the black matrix. Particularly, Yuan discloses that “the peripheral display region 21 includes a
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`black matrix (BM) 24 .
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`.
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`., and sub-pixels in the peripheral display region 21 are partially covered
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`by the black matrix 24.” Yuan, paragraph [0033].
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`In a similar manner, Yuan provides that FIG.
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`6 illustrates that “the peripheral display region is partially covered by a black matrix 64.” Id.,
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`paragraph [0060]. Yuan specifically provides that the first to fourth sub-pixels are provided so
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`that the “light-transmitting ratios of various types of sub-pixels in the peripheral display region
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`shown in FIG. 6 are approximately the same.” Id.
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`In other words, the embodiments of the color
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`11
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`

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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
`
`filter substrate of Yuan are provided to address display region imbalance in the peripheral
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`display region due to black matrix (24, 64) covering at least a part of the peripheral display
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`region.
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`First, Applicant respectfully submits that the combination of Hickl and Yuan in the
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`manner claimed is based on impermissible hindsight, contrary to the guidance of MPEP § 2142,
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`which states that “impermissible hindsight must be avoided and the legal conclusion must be
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`reached on the basis of the facts gleaned from the prior art”. “‘Anyjudgement on obviousness
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`is in a sense necessarily a reconstruction based on hindsight reasoning, but so long as it takes
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`into account only knowledge which was within the level of ordinary skill in the art at the time the
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`claimed invention was made and does not include knowledge gleaned only from applicant’s
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`disclosure, such a reconstruction is proper’” (MPEP § 2145(X)(A), quoting In re McLaughlin, 443
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`F.2d 1392, 1395 (CCPA 1971).
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`Here, as proffered, Hickl, as a whole, provides embodiments that address expansion
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`and movement of the tile display, but does not address optical characteristic of the seamless
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`tiled display. Furthermore, the peripheral area of the tile display are not covered by black matrix.
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`On the other hand, Yuan discloses that the arrangement of the pixels are provided to address
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`the optical issues caused by the peripheral display being covered by the black matrix.
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`Therefore, neither Hickl nor Yuan provides an objective reason to combine them in the
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`manner combined. The Office Action alleges that it would have been obvious to incorporate the
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`pixel color arrangement of Yuan into Hickl “to improve quality of the color filter substrate and
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`enhance visual effects of the display device.” Office Action, at 4. However, neither Hickl nor
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`Yuan provide any evidence that combination of the pixel color arrangement of Yuan into Hickl
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`may provide any improvement to the seamless tiled display since the tile displays of Hickl does
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`not have any peripheral area partially covered by black matrix.
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`If this hindsight-based,
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`conclusory analysis may support a prima facie case of obviousness, any form of optical
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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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`improvement may be adopted into Hickl, regardless of whether Hickl includes such structure to
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`improve from or not.
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`Furthermore, when evaluating claims for obviousness, “the prior art as a whole must be
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`considered. The teachings are to be viewed as they would have been viewed by one of ordinary
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`skill.” In re Hedges, 783 F.2d 1038, 1041 (Fed. Cir. 1986). Thus, “‘[i]t is impermissible within the
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`framework of section 103 to pick and choose from any one reference only so much of it as will
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`support a given position, to the exclusion of other parts necessary to the full appreciation of
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`what such reference fairly suggests to one of ordinary skill in the art.”’ Id. (quoting In re
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`Wesslau, 353 F.2d 238, 241 (CCPA)).
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`Here, Yuan specifically discloses that the arrangement of the pixels are provided to
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`address the optical issues caused by the peripheral display being covered by the black matrix.
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`Therefore, it is impermissible within the framework of section 103 to pick and choose
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`from Yuan only so much the pixel color arrangement, to the exclusion of the structure of the
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`black matrix provided to shape the display area, which is the underlying structure necessary to
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`the full appreciation of what Yuan fairly suggests to one of ordinary skill in the art.
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`Thus, Applicant respectfully submits that the Office Action fails to establish a prima facie
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`case of obviousness of claim 1 at least because the Office Action fails to provide a persuasive
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`reason to combine Hickl and Yuan in the manner claimed.
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`Additionally, without conceding the correctness of the rejection, claim 1 has been
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`amended to recite, inter alia:
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`a display area comprising:
`a first sub-area comprising at least one first pixel unit; and
`at least one second sub-area disposed to adjoin and to surround the first sub-
`area, the at least one second sub-area comprising at least one second pixel unit,
`a first gate line extending in a first direction, and a second gate line extending
`in the first direction; and
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`wherein the at least one second pixel unit further comprises:
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`13
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`

`

`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
`
`a fourth pixel, a fifth pixel, and a sixth pixel, each of the fourth pixel, the fifth
`pixel, and the sixth pixel being configured to display a white color,
`wherein the fourth pixel of the at least one second pixel unit, the fifth pixel of
`the at least one second pixel unit and the sixth pixel of the at least one second pixel
`unit are sequentially arranged in the first direction,
`wherein the first pixel of the at least one second pixel unit, the second pixel of
`the at least one second pixel unit and the third pixel of the at least one second pixel unit
`are electrically connected to the first gate line,
`wherein the fourth pixel of the at least one second pixel unit, the fifth pixel of
`the at least one second pixel unit and the third pixel of the at least one second pixel unit
`are electrically connected to the second gate line, and
`wherein the second gate line is disposed between the non-display area and the
`first gate line in a second direction perpendicular to the first direction.
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`(Emphasis added) It is respectfully submitted that, even if combined, Hickl and Yuan fail
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`to disclose or suggest every claimed feature of claim 1, as amended.
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`B.
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`Claim 7
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`Claim 7 recites, inter alia:
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`wherein each of the at least one first pixel unit, the at least one second
`pixel unit, the at least one third pixel unit, the at least one fourth pixel unit, and
`the at least one fifth pixel unit comprises:
`a first pixel configured to display a first color;
`a second pixel configured to display a second color; and
`a third pixel configured to display a third color, the first, second,
`and third colors being different from one another, and
`wherein each of the at least one second pixel unit, the at least one
`third pixel unit, the at least one fourth pixel unit, and the at least one fifth
`pixel unit further comprises:
`at least one fourth pixel configured to display a white color.
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`(Emphasis added) The Office Action rejected claim 7 for the same reasons proffered
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`regarding claim 1. See Office Action, at 2-5. Applicant respectfully submits that, for
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`substantially the same reasons proffered regarding claim 1, that the Office Action fails to provide
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`a persuasive reason to combine Hickl and Yuan in the manner claimed.
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`Additionally, without conceding the correctness of the rejection, claim 1 has been
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`amended to recite, inter alia:
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`14
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`

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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
`
`a second sub-area comprising at least one second pixel unit disposed to adjoin a
`lower side of the first sub-area, a first gate line extending in a first direction and a
`second gate line extending in the first direction;
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`wherein the at least one second pixel unit further comprises:
`a fifth pixel and a sixth pixel, the fifth pixel and the sixth pixel being configured to
`display the white color,
`wherein the fourth pixel of the at least one second pixel unit, the fifth pixel of
`the at least one second pixel unit and the sixth pixel of the at least one second pixel
`unit are sequentially arranged in the first direction,
`wherein the first pixel of the at least one second pixel unit, the second pixel of the
`at least one second pixel unit and the third pixel of the at least one second pixel unit are
`electrically connected to the first gate line,
`wherein the fourth pixel of the at least one second pixel unit, the fifth pixel of the
`at least one second pixel unit and the third pixel of the at least one second pixel unit are
`electrically connected to the second gate line, and
`wherein the second gate line is disposed between the non-display area and the
`first gate line in a second direction perpendicular to the first direction.
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`(Emphasis is added) It is respectfully submitted that, even if combined, Hickl and Yuan
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`fail to disclose or suggest every claimed feature of claim 7, as amended.
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection
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`of claims 1 and 7. Since claims 2, 3, 6, 8, and 20 depend from claims 1 and 7, they should also
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`be allowable for at least the same reasons supporting allowance of claims 1 and 7. Since none
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`of the other prior art of record, whether taken alone or in any combination, discloses or suggests
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`all the features of the claimed invention, Applicant respectfully submits that independent claims
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`1 and 7, and all the claims that depend therefrom, are allowable.
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`Claims 4, 5, 9-15, 18 and 19 stand rejected under 35 U.S.C. § 103 as being allegedly
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`unpatentable over Hickl in view of Yuan and further in view of US. Patent Application
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`Publication No. 2013/0027439 applied for by Kim et al. (“Kim”). Applicant respectfully traverses
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`this rejection for at least the following reasons.
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`Applicant respectfully submits that claims 1 and 7 are allowable over Hickl and Yuan,
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`and Kim fails to cure the deficiencies of Hickl and Yuan noted above with regard to claims 1 and
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`15
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`

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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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`7. Hence, claims 4, 5, 9-15, 18 and 19 are allowable at least because they depend from
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`allowable claims 1 and 7. Accordingly, Applicant respectfully requests withdrawal of the 35
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`U.S.C. § 103 rejection of claims 4, 5, 9-15, 18 and 19.
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`Claim 16 stands rejected under 35 U.S.C. § 103 as being allegedly unpatentable over
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`Hickl in view of Yuan and further in view of U. 8. Patent No. 6,014,121 issued to Aratani et al.
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`(“Aratani”). Applicant respectfully traverses this rejection for at least the following reasons.
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`Applicant respectfully submits that claim 7 is allowable over Hickl and Yuan, and Kim
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`and Aratani fail to cure the deficiencies of Hickl and Yuan noted above with regard to claim 7.
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`Hence, claim 16 is allowable at least because they depend from an allowable claim 7.
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection of claim
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`16.
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`Claim 17 stand rejected under 35 U.S.C. § 103 as being allegedly unpatentable over
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`Hickl in view of Yuan, further in view of Kim, further in view of Aratani, further in view US.
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`Patent Application Publication No. 2014/0211103 applied for by Baek et al. (“Baek”). Applicant
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`respectfully traverses this rejection for at least the following reasons.
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`Applicant respectfully submits that claim 7 is allowable over Hickl and Yuan, and Kim,
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`Aratani, and Baek fail to cure the deficiencies of Hickl and Yuan noted above with regard to
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`claim 7. Hence, claim 17 is allowable at least because they depend from an allowable claim 7.
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`Accordingly, Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection of claim
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`17.
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`Claims 21 and 22 stand rejected under 35 U.S.C. § 103 as being allegedly unpatentable
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`over Hickl in view of Yuan and further in view of US. Patent Application Publication No.
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`16
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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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`2016/0055821 applied for by Phan et al. (“Phan”). Applicant respectfully traverses this rejection
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`for at least the following reasons.
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`Applicant respectfully submits that claims 1 and 7 are allowable over Hickl and Yuan,
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`and Phan fails to cure the deficiencies of Hickl and Yuan noted above with regard to claims 1
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`and 7. Since claims 21 and 22 depend from allowable claims 1 and 7, they should also be
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`allowable for at least the same reasons supporting allowance of claim 21 and 22. Accordingly,
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`Applicant respectfully requests withdrawal of the 35 U.S.C. § 103 rejection of claims 21 and 22.
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`Other Matters
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`In addition to the amendments mentioned above, claim 16 has been amended for clarity.
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`These amendments are not made to avoid prior art or narrow the claimed invention, and no
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`change in claim scope is intended. Therefore, Applicant does not intend to relinquish any
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`subject matter by these amendments.
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`17
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`Application No.: 16/102,615
`Reply dated April 22, 2020
`Response to Office Action of February 5, 2020 and an Advisory Action of April 9, 2020
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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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`NVon Suk Hwangl
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`Won Suk Hwang
`Reg. No. 69,501
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`Date: April 22, 2020
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`CUSTOMER NUMBER: 58027
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`HO. Park & Associates, PLC
`1894 Preston White Drive
`
`Reston, VA 20191
`Tel: 703-288-5105
`Fax: 703-288-5139
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