Mirror Worlds, LLC v. Apple, Inc.

Filing 160

CLAIM CONSTRUCTION RESPONSE BRIEF re: #151 Mirror Worlds' Claim Construction Brief, filed by Apple Inc. (Attachments: #1 Decl. of Stefani C. Smith ISO Apple's Brief, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L)(Smith, Stefani) Modified on 1/11/2010 (mll, ).

Mirror Worlds, LLC v. Apple, Inc.

Doc. 160 Att. 4

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I N T H E U N I T E D S T A T E S P A T E N T AND T R A D E M A R K O F F I C E

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b~-/~1?

Applicants S e r i a l No. Filed For

E r i c FREEMAN a n d D a v i d H. GELERNTER 08/673,255 June 28, 1996 Group Art Unit: 2771
Examine~:

W. A m s b u r y

DOCUMENT STREAM OPERATING SYSTEM 1185 Avenue of the Americas New Y o r k , New Y o r k 1 0 0 3 6 May 3 , 1 9 9 9

Assistant Commissioner of Patents Washington, D.C. 20231

RECEIVED
AfAY 1 1 1999 GrolJQ 2

AMENDMENT UNDER 3 7 C . F . R . § 1 . 1 1 5 I N RESPONSE TO NOVEMBER 3 , 1 9 9 8 O F F I C E ACTION

700

This Amendment i s f i l e d i n response t o a November 3, 1998 Office Action and a January 19, 1999 Interview concerning the present application. A response' to the Office Action was due February 3, 1999. A three-month extension of time has been requested. Accordingly, a response t o the Office Action i s now d u e May 3 , filed. 1999. Accordingly, t h i s Amendment i s being timely

I N THE CLAIMS

As i n d i c a t e d below, p l e a s e amend claims 1, 8, "[]" and by inserting the underlined text. The Amendment, remaining claims are unchanged from

10, 12, 14,

15, 17, 21, and 23-27 by deleting the text in the square brackets the previous

but are included below to present a l l

the pending

claims in one document.

!

I

/

APMW0015203

Dockets.Justia.com

227 CFH 755

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER S e r i a l N o . : 08/673~255 Filed: June 28, 1996 Page 2

--1.

(Three. Times Amended)

A computer system (for organizing]

which organizes each data unit received by or generated by the computer system, comprising: means for generating [one or more] a main stream of data [unit streams] units and at least one substream, the [data unit streams including a] main [data unit] stream for receiving each data unit received by or generated by the computer system, and each substream for stream; means for receiving [each data unit] data units from other computer systems; means for generating data units by the computer system; means for selecting a timestamp to i d e n t i f y each data u n i t ; means for associating each data unit with at least one chronological indicator having the respective timestamp; means for (linking] including each data unit according to the timestamp in the respective chronological indicator [so as to include each data unit] stream; and means for [storing each data unit stream according to the maintaining the main stream and the chronological indicators] in [at least] the main [data unit] containing data units only from the main

substrearns as persistent streams.---2. (Unchanged) is The computer system of 'claim 1, wherein each from the group consisting of: past,

timestamp

selected

present, and future times.---4. (Unchanged) The computer system of claim 1, wherein each

data unit includes textual data, video data, audio data and/or multimedia data.--

APMW0015204

227 CFH 756

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 3

--6 _

(Unchanged)

The computer system of claim 1,

wherein the

means for receiving further comprises means for receiving data u n i t s from the World Wide Web.---7. (Unchanged) The computer system of claim 1, wherein said

means for receiving further comprises means for receiving data units from a c l i e n t computer.--

15-1 -

(Three

Times

Amended)

A method

[for

organizing]

which

organizes each data unit received by or generated by a computer system, comprising the steps of: generating [one or more] a main stream of data [unit streams] units and at least one substream, the [data unit streams including a] main [data unit] stream for receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; receiving [each data unit] data units from other computer systems; generating data units in the computer system; selecting a timestamp to identify
~ach

data unit;

associating each data unit with at least one chronological indicator having the respective timestamp; [linking] including each data unit according to the timestamp in the and [storing each data unit stream according to the chronological indicators] maintaining at least the main stream and the substreams as persistent streams.---9. (Unchanged) The method of claim 8, wherein each timestamp
~espective

chronological indicator

[so as to

include each data unit] in at least the main [data unit] stream;

APMW0015205

227 CFH 757

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 4

i s selected from the group consisting of: ·future times.--

past,

present,

and

!Ko.
the --11.

(Twice Amended) The method of claim [data uni t]

J,

/j
further comprising display

step of displaying the

streams on a

device as visual streams.-(Unchanged) The method of claim 8, wherein each data unit

includes textual data, video data, audio data and/or multimedia data.-· l- w . T l m e s A m e n d e d ) T h e m e t h o d o f cla l m 7i''l/~ h e r e l n t h e step of displaying the [data unit] streams further comprises the

- - } t oIt,( T h r e e

.

steps of: a) receiving from a user one or more indications of one or more selected segments of the [data unit] streams corresponding to one or more selected intervals of time, and b) displaying the s e l e c t e d segments.--

~~~.

(Twice Amended) A computer system f o r o r g a n i z i n g each d a t a means for generating [more than one data unit] a main

unit received by or generated by the computer system, comprising: stream of data units and at least one substream, the main stream for receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; means for associating each data unit with at least one chronological indicator having a respective timestamp units] which identifies the data unit; means for [chronologically linking] including each data unit [to other data according to the timestamp in a respective chronological indicator in the main stream; means for [storing each data unit

APMW0015206

227 CFH 758

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 5

stream according to the chronological indicators] maintaining the main stream and substreams as persistent streams; means for generating a data unit having indicia to allow access to a first stream; means for including the data unit having the i n d i c i a in the second [data unit] stream; and means for providing access t o the f i r s t the second [data unit] stream in indicia. -[data unit] stream with the accordance [data unit] stream from a second [data unit]

(\ '5
\.,.,

~.

( ) from

~

--y".

)-1.(
(Twice Amended) A computer system according to claim

,:l:!;

}4

further comprising: means for providing limited access to the f i r s t stream from the second [data unit] unit indicating access privileges stream.---16. (Unchanged) The computer system according to claim 1, to the first [data unit] [data unit] stream by generating a data

further comprising: means for displaying a l t e r n a t i v e versions of the content of the data units.--

_Iy·

(Twice Amended)

A computer system according to claim 1

further comprising: means for summarizing the contents of data units in [a data unit stream] one of the streams to generate one or more overview data units and for including the overview data unit in one of the streams.--

--J,ki.

1
(Twice Amended) A computer system according to claim 1

APMW0015207

227 CFH 759

..
A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 6

further comprising: means point while for archiving the a data unit associated with a [chronological indicator] timestamp older than a specified time retaining respective chronological indicator and/or a data unit hav·ing a respective alternative version of the content of the archived data unit.--

--y!o

~

(Twice Amended) A computer system according to claim

wherein the means for summarizing further comprises means for continuously updating the overview data units to include changes in the contents of data units in the summarized.-[data unit] stream being

--~.

/~

8
(Twice Amended) The method of c l a i m ' , further comprising providing access to a f i r s t [data unit] stream from a second

the step of: [data unit] stream by generating a data unit indicating the f i r s t [data unit] stream.--

J
the

i
(Twice Amended) The method of claim steps of: selecting access privileges providing access to the first

--~.

fi,

1'3
further comprising first [data

to provide to a [data unit]

unit] stream from a second [data unit] stream; and stream from the second [data unit] stream according to the access privileges.---22. (Unchanged) The method of claim 8, further comprising the displaying data from one of the data units in abbreviated form.-..- - - -

step of:

APMW0015208

227 CFH 760

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 7

~1~·.

(Twice Amended) The method of c l a i m j t ! J f u r t h e r comprising summarizing the contents of data units in a [data unit] including

the step of: stream to generate one or more overview data units and the overview data unit in one of the streams.--

--_._---------------------::------------------j4~(Amended) T h e m e t h o d o f claim~;3further c o m p r i s i n g t h e
step of: archiving data units having [chronological indicators] timestamps older than a specified time point.---,75'./O(Amended) The computer system of claim 1, wherein the

computer program further comprises: means for operating on any of the streams using a [one] set of operations [for operating on a l l data units regardless of the type of timestamp in the respective chronological indicator, the type of timestamp selected from the group consisting of past, present, and future times] selected by a u s e r . - -

tf --2jf.

(Amended)

The

computer

system

of

claim

1

further

comprising: means to generate [additional data unit streams] substreams from existing [data unit streams] substreams.--

--~~Amended)

A computer system for organizing each data unit stream for

received by or generated by the computer system, comprising: means for generating [at l e a s t one data unit] a main

of data units and a t least one substream, the main stream

receiving each data unit received by or generated by the computer system, and each substream for containing data units only from the main stream; means for associating each data unit with a t

APMW0015209

227 CFH 761

"".1'

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 8

least one chronological indicator having a respective timestamp which units] identifies the [respective] data unit; means for [chronologically linking] including each data unit [to other data according to the timestamp in a respective chronological indicator in the main stream; means for [storing each data unit stream according to the chronological indicators] maintaining the main stream and the substreams as a persistent streams;

Cn
~

.

means for representing one or more data units of a selected unit] stream each on a display device as document the document representation including

(fiY'eJ-' r e p r e s e n t a t i o n s ,

[data

timestamp of the respective data unit and the order of appearance of each data representation on the display device determined by the timestamp of the respective data unit; means for selecting which data units are represented on the display device by selecting one of the document representations and displaying document representations corresponding to data units having timestamps within a range of a timepoint; and means for selecting one or more of the document representations with a pointing device so that the data units represented by the selected document representations are further displayed with a second document representation comprising an alternative version of the content of the respective data unit.---28. (Unchanged) A computer system as in claim 27, wherein the

document representations form a visual stream having a threedimensional effect.---29. (Unchanged) A computer system as in claim 27, wherein each a polygon and the polygons

document representation comprises

overlap to form a visual stream of polygons.--

.--.~~--.

APMW0015210

227 CFH 762

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 9

--30.

(Unchanged) A computer system as in claim 28, wherein the

three-dimensional effect further comprises a perspective view.---31. (Unchanged) A computer system as in claim 27, wherein the

alternative version is an abbreviated version.--32. (Unchanged) A computer system as in claim 27, wherein the

alternative version is a caption version.--33. (Unchanged) A computer system as in claim 27, wherein the

alternative version is an expanded version.--34. (Unchanged) A computer system as in claim 27, further

comprising: means for selecting one or more a l t e r n a t i v e versions of the content of a respective data unit to display another alternative version of the content of the data unit.---35. (Unchanged) A computer system as in claim 1, further

comprising: means for generating a data unit comprising an a l t e r n a t i v e version of the content of another data unit; and means for associating the alternative version data unit with the chronological indicator of the another data unit.---36. (Unchanged) A computer system as in claim 27,
~o

further

comprising: means for updating the display device representation for data units provide a document with chronological associated

indicators having timestamps which become the present time.--

APMW0015211

227 CFH 763

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 10

REMARKS

Claims

1-2,

4,

6-12,

and

14-36

were

pending

in

this

application. Claims 1, 8, 10, 12, 14, 15, 17-21 and 23-27 have been amended by t h i s These address Examiner; Remarks
~endment.

Accordingly, claims 1-2, 4, 6into three sections: (1) a the

12, and 14-36 are presently being examined. are divided in a discussion of amendments concerns (2) a raised to the claims and definitions which telephonic and (3) Interview with

g e n e r a l d i s c u s s i o n o f how t h e a m e n d e d c l a i m s a specific discussion

distinguish over the cited art;

addressing each rejection in the Office Action. A. I n t e r v i e w D i s c u s s i o n Applicants wish to thank the Examiner for extending the courtesy of a telephonic Interview on January 19, 1999. During the Interview, the Examiner expressed concern about the breadth of coverage of the claims because of inherent ambiguity in the claim language. these concerns Summary Applicants agreed to amend the claims to address as stated by the in the January "[i]t 19, 1999 Interview that Examiner: was agreed

prepared

Applicants would refine the claim language in the direction of addressing that stream of documents (in the broadest sense) that are of significance to the user and which thus determine the events of direct user interest in the timeline of a computing system, .without regard to whether their generation is external or internal." Primarily, of documents among other amendments discussed more fully below, applicants have amended the claims to r e c i t e the stream (data units) of significance to the user (in the broadest sense) by reciting that "each data unit received by or

APMW0015212

227 CFH 764

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 11

generated by stream".

the

computer

system"

is

received by

the

"main

In other words, a l l the data units, without regard to F u r t h e r m o r e , t h e a m e n d e d c l a i m s now

whether a data u n i t was generated i n t e r n a l l y or e x t e r n a l l y , are of significance to the user. in claim 26). stream". e x p l i c i t l y r e c i t e "substreams" (which were formerly r e c i t e d only Substreams contain "data units only from the main Accordingly, substreams allow a user to determine the

events of d i r e c t user i n t e r e s t from the stream of data units of significance to the user (main stream). Also, to c l a r i f y key terms in the amended claims which were also discussed during the interview, (1) A "data u n i t " i s a contain any type of data", present specification. (2) A "stream" i s a time-ordered sequence of documents (data units) that functions as a virtual object (diary), see page 11, lines data 11-12 units, of the present page 13, specification. lines 19-22 A stream can of the be p e r s i s t e n t , t h a t i s , dynamically updated by t h e a d d i t i o n o f new see present specification. (3) A "main stream" i s a type of stream which receives every data unit received by (external) or generated by (internal) the computer (4) system, see page 11, lines 13-15 of the present specification. A "substream" i s a type of stream having one or more data units only from the main stream, see page 14, lines 7-10 of the present specification. (5) A "timestamp" i s a date/time used to uniquely i d e n t i f y each data unit, see page 12, lines 6-7 and page 20, lines 14-20 of the present specification. Note: a counter which overflows definitions based on the present specification are provided below. 'document' because a "document can see page 11, lines 20-22 of the

APMW0015213

227 CFH 765

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 12

periodically can not be a timestamp, since the timestamp would then not uniquely identify a data unit. Thus, applicants have amended the claims and indicated where in the specification the breadth key of terms the are defined matter to more of the clearly present express subject

invention and to remove any ambiguities. B. General Discussion In referred this to Amendment, by the each of form the following in documents are short provided the parenthesis

following the full t i t l e of the document: (1) "The Cyber-Road Not Taken" by David G e l e r n t e r from The Washington Post dated April 3, 1994 (2) U.S. Patent No. ("Tobias"); (3) "Getting Results with Microsoft Outlook 97", pp. 28-29 ("Outlook") ; (4) U.S. P a t e n t No. 5 , 2 9 7 , 0 3 2 t o T r o j a n e t a l . and (5) Robert Cowart, "Mastering WindowsTM 3.1 Special Edition", Chapter 12, pp. 398-417 (1993) Article briefly (data describes units). a new way ("Cowart"). to organize shifts computer away from such as ("Trojan"); ("Gelernter Article"); to Tobias, II et al. 5,530,859

Applicants note· that the paradigm set forth in the Gelernter documents This paradigm

conventional "lifestream".

computer document

organization schemes,

provided by Windows 95, by presenting a v i r t u a l o b j e c t c a l l e d a Indeed, the Gelernter Article teaches away from according to the Gelernter Article, to graphically access and archives the being combined with "files" of a conventional computer system. This lifestream, and allows a (stores) documents received by a user in a chronological order user display

APMW0015214

227 CFH 766

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 13

documents. While the paradigm described in the Gelernter- Article i s useful, the present invention, as recited in the amended claims, p r e s e n t s new a n d u n o b v i o u s i n n o v a t i o n s f o r t h e p a r a d i g m w h i c h d o not exist in the cited art; Tobias, particularly because Trojan, and Cowart) the other references (Outlook, cited by the are not

Office Action do not teach or suggest any relationship to the streams of the paradigm. That the other references r e l a t e d t o s t r e a m s i s s h o w n b y how t h e a l l e g e d s i m i l a r t i m e l i n e s and buffers are treated in those systems. For example, none of the cited references provide for the buffer or timeline to be manipulated as a virtual object, for example, to be copied as a stream into another stream or to be summarized. Thus, applicants submit that the streams, as recited in the amended claims, are not merely buffers or timelines but include additional properties described in the specification and recited in the amended claims. Accordingly, applicants respectfully submit that the lack of any teaching or suggestion to treat the buffers or timelines of the c i t e d a r t as v i r t u a l objects show t h a t one of s k i l l i n the a r t would not be led to combine the teachings of the Gelernter Article with any of the cited references. Furthermore, a l l the pending claims recite a property of the present invention which i s not present in any of the cited a r t , including the Gelernter Article, that is, substreams containing data units only from the main stream. (a primary archival system) Such substreams take while also providing advantage the useful aspect of the lifestream of the Gelernter Article additional virtual objects, that is substreams, which provide

additional capabilities for organizing data units. As d i s c u s s e d a b o v e , t h e o n l y c i t e d r e f e r e n c e w h i c h c o n t a i n s a main stream i s the Gelernter Article. However, the Gelernter

APMW0015215

227 CFH 767

T
I
I

.-

..

I

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.; 08/673,255 Filed; June 28, 1996 Page 14

Article Indeed,

lacks the

the

substreams

recited

in

the away

amended from

claims.

Gelernter Article

teaches

substreams

because the Gelernter Article emphasizes

the simplicity of a

s i n g l e s t r e a m , " [ y ] o u r l i f e s t r e a m c a p t u r e s y o u r w h o l e l i f e . . . N, see page 4, paragraph 3 of the Gelernter Article. Although the Gelernter Article allows a user to "view [the lifestream] selectively" (emphasis added), see page 4 in paragraph 3 of the Gelernter Article, one of s k i l l in the a r t i s taught to generate the viewed portion as a simple l i s t lacking t h e dynamic p r o p e r t i e s o f a substream ( f o r example, having new data units added) runs because to generate additional of allowing a user to 'persistent "no time

I

I

i

streams', Article. In

afoul

spend

whatsoever organizing", see page 4, paragraph 2 of the Gelernter contrast to the Gelernter Article, Outlook teaches

I I
I
!
i
I

I

multiple timelines of segregated data lists. Outlook does not provide any teaching

Even i f , arguendo, or suggestion of

the timelines could be construed to be multiple main streams, substreams, which, as recited in the amended claims, contain data units only from the main stream. Indeed, one of s k i l l in the a r t i s taught by Outlook to use the multiple streams to segregate the data units as received by the computer program according to the particular application, each timeline does not timelines. such as E-mail or phone calls. include data units found in Thus, other

In contrast, the amended claims s p e c i f i c a l l y r e c i t e

that the substreams contain data units only from the main stream. Thus, even i f one were to combine the teachings of Outlook with the Gelernter Article to obtain multiple streams, streams would not include substreams. Tobias does not teach or suggest either main streams or substreams as recited in the amended claims of the present the multiple

APMW0015216

227 CFH 768

T
I I
I
I

I

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 15

invention.

Instead, Tobias teaches a timeline which does not see for example, column 18 i n l i n e s 10-21 of timeline and a may not become mayor

include every object (data unit) generated by or received by the computer system, Tobias where particular clock obj ects are placed in the object/sequence

graphic

associated with a clock object. timeline of Tobias does not

Because a graphic object which function as. a "main stream" as

is not associated with a clock object is not in the timeline, the recited in the amended claims. or suggestion of substreams. absent from Tobias. Also, Tobias lacks any teaching 'sub'-timelines which

For example,

include clock objects only found on a 'main' timeline are wholly Therefore, because neither the Gelernter Article nor Outlook teach or suggest substreams, combining Tobias with this cited art fails to teach or suggest the substreams of the present invention as recited in the amended claims. Troj an provides Trojan network, a also does buffer have data for more fails packets not have substreams. low-level buffer or found in Instead, Troj an data While sending than to one teach only communication within a the

packets of the same type between computers on a network. does Trojan suggest

computer buffer.

'sub'-buffers 'main'

containing

Therefore, even in the unlikely event that one of s k i l l in the a r t would look to the low-level buffer of Trojan for a teaching o r s u g g e s t i o n o f how t o i m p l e m e n t s u b s t r e a m s , T r o j a n f a i l s t o provide any such teaching. combine Tobias, Trojan one of with skill the in Thus, even i f , arguendo, one were to Gelernter the art Article, could find Outlook, no and/or teaching or

suggestion of substreams as r e c i t e d in the amended claims. Cowart teaches display of data units in overlapping windows. However, Cowart does not teach or suggest using such windows to display document representations of main streams or substreams.

APMW0015217

227 CFH 769

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 16

Indeed, Even

the

overlapping

windows

of

Cowart

are

part

of

an

alphabetic,

not a time-oriented, l i s t , see page 406 of Cowart.

i f one were to combine the other cited a r t with Cowart independent timelines

despite any teaching or suggestion to do so, one of s k i l l in the a r t would provide displays of separate, in the amended claims. While not explicitly cited in the Office Action, apPlicants submit that mail the present invention as recited in the amended claims is both novel and unobvious over conventional electronic (E-mail) and/or calendar applications. A conventional Email application receives electronic messages from other computer systems and places these electronic messages in the order in which the electronic messages are received in a primary queue. After the user retrieves the messages using the E-mail application, the messages can be deleted, retained in the queue, or removed from the queue for storage elsewhere in the computer system, for example, into separate text f i l e s . present invention as recited in In contrast, the not the amended claims does instead of displays of a main stream and substreams as recited

permit data units to be removed from the main stream and s t i l l remain in the computer system because, as r e c i t e d in the amended claims, a data unit of the computer system must be included in the main stream. stream, as The requirement t h a t a data unit be in the main in the amended claims, results from the recited

inherent structure of the main stream as the storage backbone of the present invention. The separate text f i l e s of a conventional E-mail system, as described above, do not operate like data units r e c i t e d in the amended claims a t l e a s t because the purpOSe of a separate text f i l e is to save the message, but without leaving the message in the primary queue of the E-mail application. Substreams, in contrast, allow a user to determine the data units

APMW0015218

227 CFH 770

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 17

~f

d i r e c t i n t e r e s t while also maintaining the data Unl't A conventional with calendar dates application and/or times allows a

in the to

main stream of the computer system. user generate historical or reminder messages, and to aSSOciate these messages into a t ' l' lme lne. Conventional calendar applications are even more limited than the specific

O u t l o o k t i m e 1 i n e a t l e a s t b e c a u s e s u c h c a l e n d a r sYst ems d 0 n o t r e c e i v e d a t a u n i t s generated from o t h e r computer sys t ems as ac k any teaching or suggestion of substreams containing data unl t s on 1 y ' from the main stream.
1

reci ted

in

the

amended

claims,

and

like

Outlook ,

Applicants allows wi thout for

also note

that

the

application-independent

data

units

use of timestarnpsof the in the present invention

an ~ i t s e l f having to be separately declared as an eVent to the For example, i f a user wishes to send an E-mail

each data unit

to be

treated as

computer system.

m e s s a g e d a t a u n i t a t 1 2 : 0 1 pm o n J u l y 4 , 1 9 9 9 a C C O r d i n g t o t h e present invention, the user need only generate a timestamp for the chronological indicator of a data unit with that time and date and the data unit will be placed a t t h a t time and date on the main stream. In contrast, an E-mail queue lacks t h i s 'future' capability, s i n c e new mail i s always Placed at the present timepoint. A l s o , w h i l e a c a l e n d a r c o m p u t e r s y s t em c a n set 'appointments' for future dates, such appointment s are only for use by the calendar computer system. In Contrast, the is not an E-mail message or a calendar unl't '"' which 'appointment', to be
dat~

timestamp of the present invention allows for a

t r e a t e d as an event such that the data unit will appear on a t least the main stream at the time and date of i t s timestamp. In addition, and both the the queue of of a a conventional E-mail application timeline conventional calendar

APMW0015219

227 CFH 771

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 18

application

ca'n

not

receive

each

data

unit

received

by

or

generated by the computer system.

For example, i f a data unit

i s not a proper E-mail message or calendar entry, such as a b i t mapped graphic having only graphic information without any E-mail message/calendar indicia, unit. the application will reject the data In contrast, the main stream of the present invention as

r e c i t e d in the amended claims receives and includes each data unit received by the computer system and provides, i f necessary, a chronological indicator and timestamp to allow the data unit to be identified and included in the main stream. In contrast, even i f an E-mail or calendar application deletes or stores a data unit of an unknown format elsewhere, such a data u n i t i s not placed in the primary queue or timeline. Thus, for at least this reason, a conventional E-mail and/or calendar system teaches away from the present invention as recited in the amended claims. Therefore, applicants submit that a conventional E-mail application, a conventional calendar application, and the cited art, taken alone or in combination, fail to teach or suggest at least the main stream and substreams recited in the amended claims.
~.

Specific Discussion Applicants have amended claims 1, 8, 10, 12, 14, 15, 17-21, 23-27 (1) to incorporate the clarifications discussed above.

and

S p e c i f i c a l l y , amended independent claims 1, 8, 14 and 27 r e c i t e that: the computer system organizes data units received or by the computer system; (2) means for generating generated

provide a main stream for receiving each data unit and at least one substream; persistent. (3) the substreams containing data u n i t s only from the main stream; and (4) the main stream and the user streams are Additionally, the claims have been amended to r e f e r data units rather than to streams of, including, or containing,

APMW0015220

227 CFH 772

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 19

"data unit streams" to more clearly r e c i t e the composition of the ·main stream and substreams. Support for amendment (1) of the independent claims can be found, inter alia, on page 11 in lines 13-14 of the present specification. Support for amendment (2) of the independent claims can be found, i n t e r a l i a , on page 11 i n l i n e s 13-14 and on page 13 in lines 8-13 of the present specification. Support for amendment (3) of the independent claims can be found, inter alia, on page 13 in lines 8-13 of the present specification. Support for amendment (4) of the independent claims can be found, inter alia, 12, 23 on page 13 15, 17-21, in lines 19-22 of the present specification. Claims 10, claims 17 and data and 23-26 have been amended to Further, that the and recite main conform to the modifications of claims 1, 8, and 14. also have been amended to included in the overview units are

stream

substreams.

Support for t h i s amendment can be found, i n t e r a l i a , Claims

on page 14 i n l i n e s 12-24 o f t h e p r e s e n t s p e c i f i c a t i o n .

1, 14, 18, 24 and 27 a l s o have been amended t o more c l e a r l y r e f e r to the timestamp in the chronological indicator as recited in claim 8. Support for t h i s amendment can be found, in lines inter alia, In on page 12 13-23 of the present specification.

a d d i t i o n , claim 25 has been amended t o r e c i t e t h a t the operations on the data units are selected by a user _ the present specification. Section 2 of the Office Action rejects claims 1-2, 6-10, 12, and 14-36 under 35 U.S.C. §112, second paragraph, as being indefinite. According to the Office Action, "each data unit" is Support for this amendment can be found, i n t e r a l i a , on page 12 in l i n e s 11-23 of

APMW0015221

227 CFH 773

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 20

intended by the specification to have "predetermined a t t r i b u t e s for particular applications, Applicants clearly recite hereinabove that the but that in the claims,
H

H

the data

units are interpreted as "each data unit received have amended a l l are both

by a stream. independent

the

claims, and therefore implicitly, a l l the other claims, to more data units received by or generated by the computer system, see for example, the calling cards (access data units) and browse cards (overview data units) discussed i n present s p e c i f i c a t i o n from page 21, l i n e 22 t o page 2 3 , l i n e 1 9 , and on p a g e 14 i n l i n e s 1 2 - 2 4 . Further, the data units, as have "predetermined attributes
H

recited, are not required to for particular applications.

Instead,

as s t a t e d on page 11 in lines 11-22 of the present
H

specification, a data unit "can contain any type of data H related to "an entity's electronic life. submit that the term "data unit
H

Thus, applicants respectfully as recited in the amended claims

is consistent with the present specification, that is, each unit is received by or generated by the computer system and thus, i s not indefinite. In view of the amendments and the remarks above, applicants respectfully request that the rejection of claims reconsidered and withdrawn. Section 3 of the Office Action rejects claims 1-2, 4, 6-12, and 14-36 under 35 1-2, 6-10, 12,
H

and 14-36 as being indefinite with respect to "data units

be

u. S. C.

§112,

second
H

paragraph,

as

being

indefinite.

According to the Office Action, the recitation of in at least claims 2 and However, the

timestamps as "past, present and future

12 i s ambiguous, since past, present and future are categories implying separate storage for the three categories. Office Action notes that the claims recite a computer system having only one stream which would have to include a l l three

APMW0015222

227 CFH 774

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 21

categories. Applicants respectfully submit that the past, present, and future time. timestamps are not categories, but, as recited in the for to amended claims, are indications of the three possible types of The amended claims do not mean separate c a t e g o r i e s but were provided in at least claims 2 and 9 storage,

explicitly distinguish over present-to-past archive systems that do not provide for the future. present and future", see page Indeed, the present specification 15 a t line 18 of the present specifically refers to streams having "three main portions: past, specification. Thus, as stated in the specification, the past,

present, and future timestamps are not storage categories, but refer to types of timestamps that are found in a stream. In view of these remarks and the general remarks above, applicants respectfully request that the rejection of claims 2, 4, 6-10, "past, present, and future" be reconsidered and withdrawn. Section 4 of the Office Action generally comments on the arguments of the previous Amendment noting the ambiguities discussed in Sections 2 and 3 of the Office Action and also s t a t e s that by tagging the data units in chronological order provides for storage by "implicit or e x p l i c i t linking", and that any other type of storage for data units so tagged would require "proactive intervention". Applicants have already addressed the ambiguities with respect to Sections 2 and 3. Because, as noted above, neither 112, and 14-36 as being indefinite with respect to

the specification nor the claims recite or discuss the present invention as organizing the data units in any order other than chronological order, applicants respectfully submit that the comments in Section 4 of the Office Action relating to "proactive intervention" for alternative tagging are moot.

APMW0015223

227 CFH 775

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 22

Section

5

of

the

Office

Action

maintains

the

previous According

r e j e c t i o n of claims 1-2, 4, and 8-11 under 35 U.S.C. °102(b) as being clearly anticipated by the Gelernter Article. to the Office Action, applicants fail to appreciate the breadth of the claims as noted in Sections 2-4 of the Office Action, which reads on the Gelernter Article. that the Gelernter Article provides The Office Action s t a t e s a "stream of data of Also,

i n t e r e s t " to the user and means to display such a stream. not intend to include future events is "not tenable".

the Office Action notes that the argument that the inventor did Applicants hereinabove have amended claims 1, 8, 14 and 27 to recite "substreams": the substreams containing data units only from the main stream. As discussed above in the General Discussion, although the Gelernter Article teaches a stream of data units, the Gelernter Article also teaches away from having substreams because substreams which, unlike a listing, are persistent, complicate the computer system and therefore require time for "organizing one's life". nei ther teaches nor suggests Thus, the Gelernter Article in the art to to one of s k i l l

include substreams as r e c i t e d in the amended claims. In addition, with respect to claims 2 and 9, the inventor, David Gelernter stated during the Interview, that he conceived an "archive" (present-to-past) system at the time of the Dr. Gelernter A r t i c l e , and was not considering future events. such an Affidavit would be helpful. In view of the amendments and the remarks above, applicants respectfully request that the rejection of claims 8-11 as being 6 anticipated of the Office by the Gelernter maintains reconsidered and withdrawn. Section Action the previous 1-2, 4, and Article be

Gelernter i s willing to provide an Affidavit to this effect i f

APMW0015224

227 CFH 776

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 23

rejection of claims 6-7, 103(a) as being

12,

16-19, and 22-24 under 35 over the Gelernter

u.s.c.

unpatentable

Article.

According to the Office Action, sections 2-4 of the Office Action d e m o n s t r a t e how t h e s e c l a i m s a r e u n p a t e n t a b l e o v e r t h e G e l e r n t e r Article. As noted above with r e s p e c t to Section 5 of the Office Action, a p p l i c a n t s hereinabove have amended claims 1, 8, 14 and 27 t o r e c i t e t h a t "substreams" containing data u n i t s only from the main stream are generated by the computer system of the present invention, Article. Since each of the claims rejected in Section 6 unpatentable for at least the reasons discussed
i~

which i s taught away from by the Gelernter dependent with

on one of these independent claims, each of these claims i s not above respect to Section 5. In view of the amendments to the claims and the remarks above, claims applicants 6-7, 12, respectfully request 16-19, and 22-24 as that the rejection of over the unpatentable

Gelernter ArtIcle

be reconsidered and withdrawn.

Section 7 of the Office Action rejects claims 1-2, 4, and 8-12 under 35 U.S.C. 102(a,e) as being a n t i c i p a t e d by, and claims 6-7, 16-19, and 22-24 under 103(a) as being unpatentable over, The Office Action s t a t e s t h a t the r e j e c t i o n made in the previous Office Action is maintained and refers to sections 2-4 of the Office Action. In particular, the Office Action states t h a t Tobias has a timestamp as found in the amended claims. Applicants have amended a l l the independent claims 1, 8, 14 and 27, and therefore implicitly, a l l the claims, to more clearly recite subject matter of the present invention by reciting that the main stream includes each data unit. In Tobias, in contrast, Tobias.

APMW0015225

227 CFH 777

:. '.~

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 24

data units can be placed in none, one, or more timelines. for at least this reason. More s p e c i f i c a l l y ,

Thus,

the amended claims are not anticipated by or obvious over Tobias applicants note that only the special Other

clock data structures of Tobias are placed on a timeline. be activated as an event at a particular time.

data units must be associated with the clock data structures to In contrast, the independent claims of the present invention recite that each data unit has a timestamp placed in i t s chronological indicator and that each data unit i s placed in the main stream. Thus, instead of a timeline composed solely of special data structures having timestamps, every data unit of the present invention is related to a timestamp in a chronological indicator. Tobias, one would only assign timestamps Accordingly, i f one to those data units The present of s k i l l in the a r t were to use the suggestions and teachings of which need t o be assigned a time for some purpose.

invention, in contrast, assigns a timestamp to each data unit at least for identification purposes, thereby permitting each data unit to be treated as an event without having to be associated with a special clock data structure. Further, as set forth in the General Discussion, Tobias also fails to teach or suggest substreams having data units only from a main stream as recited in the amended claims. In view of the amendments and remarks above, as being anticipated by, and claims 6-7, 16-19, applicants respectfully request that the rejection of claims 1-2, 4, 8-12 and 22-24 as being unpatentable over, Tobias be reconsidered and withdrawn. Section 8 of the Office Action rejects claims 1-2 and 6-10 under 35 U.S.C. l02(a) as being a n t i c i p a t e d by, and claims 4, 9, 11-12, 16-19, and 22-24 under U.S.C. 103(a) as being unpatentable over, Outlook.

APMW0015226

227 CFH 778

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 25

,.
The Office Action s t a t e s t h a t the rej e c t i o n made i n the previous Office Action is maintained and refers to sections 2-4 of the Office Action. according Also, to The Office Action also s t a t e s the time the user last worked that an on the explicit timestamp must be present because a user can locate a document document. time." Applicants hereinabove have amended a l l the independent claims 1, 8, 14 and 27, and t h u s , i m p l i c i t l y a l l the claims, t o more clearly recite substreams including data units only from the main stream. main to
strea~.

the office Action notes that the Journal of

Outlook i s a "data stream of varying items and i s organized by

As d i s c u s s e d i n t h e g e n e r a l r e m a r k s a b o v e , O u t l o o k Instead, Outlook teaches away from such i n c l u s i o n into categories, such as E-mail, phone calls,

does not have substreams which contain data units only from the by segregating the particular data units (which Outlook chooses accept) etcetera. stream, In contrast, the present invention as recited in the but instead requires each data unit to be present at Outlook does not have a default timeline for

amended claims does not permit any segregation from the main l e a s t on the main stream. Further, receiving any otherwise uncategorized data units. For example,

in the present invention, a word processing document, an E-mail message, and a computer game are a l l placed i n the main stream chronologically. In contrast, Outlook has no provision for placing data units in a default timeline. l e t t e r s before any chronological linkage. a single input buffer
fo~

For example, Outlook While Outlook may have such an input

pre-sorts received data units into categories, such as E-mail or receiving data units,

buffer i s not a main stream, as recited in the amended claims, a t least because Outlook does not provide a means for including

APMW0015227

227 CFH 779

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 26

the data unit in the input buffer while also placing the data uni t in a timeline category. 19, and In addition, 22-23, with respect provides to no amended claims 16-17, Outlook

mechanism for displaying or summarizing the data units in such an input buffer. In view of 9, the remarks above, applicants respectfully request that rejection of claims 1-2, and 6-10 as anticipated by, and claims 4, 11-12, 16-19 and 22-24 as unpatentable over, Outlook be reconsidered and withdrawn. Sections 9, 10, and 11 of the Office Action r e j e c t claims 14-15 and 29-21 under U.S.C. 103(a) as being unpatentable over the Gelernter Article, Tobias, or Outlook, in view of Trojan. The Office Action maintains the rejection in the previous Office Actions and refers to sections 2-4 of the Office Action. As d i s c u s s e d a b o v e w i t h r e s p e c t t o a m e n d e d c l a i m s 1 , 8 , a n d 27, A p p l i c a n t s have amended c l a i m 14 t o r e c i t e s u b s t r e a m s h a v i n g data units only from the main stream. Article, and 20-21 Also, Tobias are and Outlook not fails substreams. Trojan, like the Gelernter to teach the or suggest such

Thus, for a t l e a s t t h i s reason, amended claims 14-15 unpatentable over Gelernter Article, while

Tobias, or Outlook in view of Trojan. as p a r t i c u l a r l y r e c i t e d in amended claim 14, 'channel' Trojan describes a in terms of a particular form of

d a t a , t h a t i s , NASD d a t a , T r o j a n d o e s n o t t e a c h o r s u g g e s t t h a t these b u f f e r s a r e used t o pass o r c r e a t e non-NASD d a t a , such as pointers to such buffers. referencing is speculative. to other streams. For At best, such an a b i l i t y for buffer None of the c i t e d a r t , while Outlook including display Thus,

Trojan, discuss a stream which can contain data units that refer example, can multiple chronological lists of data units, none of the l i s t s

contain a pointer (calling card) to another of the l i s t s .

for example, clicking on an icon in Outlook's E-mail l i s t will

APMW0015228

227 CFH 780

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 27

not retrieve another E-mail l i s t .

Similarly,

the Gelernter applicants

Article and Tobias also f a i l to discuss such functionality. In view of the amendments and remarks above, respectfully request that the rejections of claims 14-15, and 2021 as being unpatentable over the Gelernter A r t i c l e , Tobias or Outlook, in view of Trojan, be reconsidered and withdrawn. Section 12 of the Office Action r e j e c t s claims 25-27 and 33 under 35 U.S.C. 102(a) as being a n t i c i p a t e d by Outlook. The Office Action s t a t e s t h a t there i s a With respect to claim 25, correspondence that the between the elements of the claims and the teachings of Outlook. the Office Action states
th~

Outlook operations are not r e s t r i c t e d by

type of timestamp.

With respect to claim 26, the Office Action s t a t e s that Outlook allows for the generation of streams for specific purposes, such as E-mail. With respect to claim 33, the Office Action s t a t e s the Office Action states, for It of separation [is] the of in part, the input to an that a message in a conventional E-mail system can be expanded. With respect to claim 27, that: " . . . Outlook clearly allows stream into multiple E-mail by timestamp. streams. In view standard practice need to allow for

attach timestamps to faxes and E-mail at the least, and to sort arbi t r a r y number of such items, to the chronological order is fixed storage structures are explicit at some claim level 26, of to from

inappropriate, and the linking together of such entries according embodiment." Applicants specifically substreams. hereinabove that have amended can be recite substreams generated

existing substreams.

Outlook fails

to teach or suggest such

Thus, for a t l e a s t t h i s reason, amended claim 26 i s

neither anticipated nor unpatentable over Outlook.

APMW0015229

227 CFH 781

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 28

Applicants hereinabove have amended claim 27 t o r e c i t e t h a t that substreams include data units from only the main stream. As discussed above with respect to Section 8 of the Office Action, applicants respectfully submit that even i f Outlook has an input buffer for receiving each data unit, such a buffer is not a "stream" as recited in amended claim 27. For example, In Outlook provides no means for displaying the input buffer. see Fig. 1 of the present specification. Thus,

contrast, the main stream of the present invention i s displayed, for at least t h e s e reasons, amended claim 27 i s not a n t i c i p a t e d by Outlook. With respect t o amended claims 25 and 33, because a claim which depends on another claim i s subject to a l l the l i m i t a t i o n s of t h a t other claim, amended claims 25 and 33 which are dependent on amended claims 1 and 27, respectively, are not a n t i c i p a t e d by Outlook for at least the same reasons discussed above with respect to amended claims 1 and 27. In view of the remarks above and the amendments to claims 25-27, and 33, applicants respectfully request that the r e j e c t i o n s of claims 25-27 and 33 as being a n t i c i p a t e d by Outlook be reconsidered and withdrawn. Section 13 of the Office Action r e j e c t s claims 31-32 and 3436 under 35 U.S.C. 103(a) as being unpatentable over Outlook. The Office Action s t a t e s t h a t there With respect to claims 31-32, while not shown in Outlook, abbreviated the art. Applicants hereinabove have amended claims 1 and 27 to recite that the substreams of the present invention include data (captioned) is a correspondence between the elements of the claims and the teachings of Outlook. the Office Action states that, display of and/or embedding with icons of or documents

versions

captions, which are used to obtain expanded versions i s known i n

APMW0015230

227 CFH 782

; . . ~.. ~-;~ ...

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 29

units only from the main stream. Since claims 31-32, and 34-36 depend on claims 1 or 27, and because a claim which depends on another claim i s subject to a l l the limitations of that other claim, applicants respectfully submit that claims 31-32, claims 1 and 27. With respect to claim 36, however, applicants also submit that one of s k i l l in the a r t would not place a future data unit, that i s , a data unit with a timestamp newer than the current time in the main stream of data units absent present invention. For example, while a the teaching of the new E-mail message and 34-36 are not unpatentable over

Outlook for at least the reasons discussed above with respect to

"pops" i n t o the display of an E-mail system when received a t the present time, neither Outlook nor any of the cited a r t , provides a means for placing the future E-mail into a stream in advance of the present time. Although Outlook allows for placement of future appointments in an appointment l i s t , this appointment l i s t w i l l n o t c a u s e t h e new a p p o i n t m e n t t o " p o p " i n t o t h e p r e s e n t t i m e of a main stream as taught by the present invention. In view of the remarks above and the amendments to claims 31-32, and 34-36, applicants respectfully request that the rejections of claims 31-32, and 34-36 as being unpatentable over Outlook be reconsidered and withdrawn. S e c t i o n 14 o f t h e O f f i c e A c t i o n r e j e c t s c l a i m s 2 8 - 3 0 u n d e r 35 U.S.C. 103(a) as being unpatentable over Outlook i n view of Cowart . . The Office Action s t a t e s t h a t there in view of Cowart. is a correspondence between the elements of the claims and the teachings of Outlook The Office Action s t a t e s t h a t the d i s p l a y of documents i n a " p e r s p e c t i v e r e p r e s e n t a t i o n s " i s w e l l known i n t h e a r t and that i t would have been obvious to one of s k i l l in the

APMW0015231

227 CFH 783

",

"."

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 30

a r t to combine Cowart with the data stream of Outlook. Applicants hereinabove have amended claim 27, claims 28-30 depend, upon which to recite that substreams of the present

invention include data units from only the main stream. Since claims 28-30 depend on claim 27, and because a claim which depends on another claim i s subject to a l l the limitations of that other claim, applicants respectfully submit that claims 28-30, are not unpatentable over Outlook for at least the reasons discussed above with respect to claims 27. displaying such windows in chronological Also, order applicants with the submit t h a t while o v e r l a i d windows a r e known i n the c i t e d a r t , timestamps is not. For example, Outlook uses separate timelines

outside of the data representations and the wjndows in Cowart are not chronologically presented. Wi t h respect to claim 30, applicants also submit Thus, that Cowart shows an orthogonal view of windows, t h a t i s , the windows do not get smaller toward the bottom of the stack. Cowart does not display a perspective view. This important distinction highlights a key aspect of the streams of the present invention, t h a t i s , as data units become older, the user considers the data less immediately important. than newer ones, would one Accordingly, only i f one of s k i l l "shrink R the size of the data
~his

in the a r t would consider older documents as being of less import displayed. In contrast, Outlook and Cowart do not recognize

key aspect of streams by teaching away from such diminishment. Indeed, both Outlook and Cowart present a l l displayed data units as the same s i z e . automatic shrinkage While one can shrink a window's size, (perspective), as such recited in the amended

claim 30 i s not performed by any of the c i t e d a r t . In view of the remarks above and the amendments to claims 28-30, applicants respectfully request that the rejections of

APMW0015232

227 CFH 784

A p p l i c a n t s : E r i c FREEMAN a n d D a v i d H. GELERNTER Serial No.: 08/673,255 Filed: June 28, 1996 Page 31

claims 28-30 as being unpatentable over Outlook in view of Cowart be reconsidered and withdrawn. In view of the remarks and amendments in t h i s Amendment, applicants respectfully request that the rejections in the Office Action be withdrawn and earnestly s o l i c i t s respectfully submit that the allowance of claims 1-2, 4, 6-12, and 14-36, as amended. Applicants subject another telephonic undersigned interview could be of assistance in advancing prosecution of the application. Accordingly, applicants' attorney invites the Examiner to telephone him at the number provided below. No f e e i s d e e m e d n e c e s s a r y i n c o n n e c t i o n w i t h t h e f i l i n g o f t h i s Amendment. However, i f any fee i s required, authorization i s hereby given to charge the amount of any such fee to Deposit Account No. 03-3125. Respectfully submitted,

I hereby c e r t i f y t h a t t h i s p a p e r i s b e i n g d e p o s i t e d t h i s d a t e with t h e u . s . P o s t a l S e r v i c e a s f i r s t c l a s s mail a d d r e s s e d t o : A s s i s t a n t Commissioner f o r P a t e n t s Washington, D.C. 20231.

~J[~
lC ar S. M, ner Reg. No. 33,970

Richard S. Milner R e g i s t r a t i o n No. 33,970 Attorney for Applicant C o o p e r & D u n h a m LLP 1185 Avenue of the Americas New Y o r k , New Y o r k 1 0 0 3 6
[phone]

APMW0015232.1

227 CFH 784.1