Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al
Responsive CLAIM CONSTRUCTION BRIEF filed by FileMaker, Inc., Pervasive Software, Inc., Symantec Corp.. (Attachments: # 1 Exhibit 1 - '216 patent, # 2 Exhibit 2 - PTO Amendment, # 3 Exhibit 3 - Reply to PTO, # 4 Exhibit 4 - Response to PTO, # 5 Exhibit 5 - PTO Notice of Reexam, # 6 Exhibit 6 - PTO Dec of Pooch, # 7 Exhibit 7 - PTO Interview Summary, # 8 Exhibit 8 - PTO Dec of Rosenblatt)(Jones, Michael)
DEFENDANTS’ RESPONSIVE BRIEF ON
1Z 1 UO IAUS
1;>1 THE UNITED STATES PATENT AND TRADEMARK OFFlCF.
Frederic B. Richardson, II[
September 21. 199J
SYSIHv! FOR SOFTWARE
David C. Cain
Group Art Unit 2202
AMENDIVIENT IN RESPONSE TO JUNE 24 1994 OFFICE ACTION
of Patents and Tradem:uks
Washing lon, D.C. 20211
rn response to the June 24, 1994 Otlice Actioll, please amend the above-capLioned
palent application as li.111ows:
IN THE CLAIMS:
Please cancel Claims
[n Claim 13, at line 1,
delete "security routine or".
Please amend Claim 1S as follow5:
'stem of Claim
17, wherein said
0 one Of/Ii
'/oIGr;h1.ernents 0 fernents WblCh are I at I east
enVironment detal01s comprise r
one element which is generally 119
September 2i, 1993
Applicant rcspcctfuUy submits that the foregoing remarks arc fully responsive to the
f~;ectiotls raised by the Examiner under 35 U.S.c. § 102 with re~ped to Chml.
respectfully requests the Examiner to withdraw the rejection of Claims 1-21,25,26 and 30
lll1der 15 U.S.c. § lO2.
Discussion of Newly Cited Rererence
The Examiner's attention is directed to U.S. 5,291,598 to Grundy submitted herewith
and identified on form P'TO-1449.
The Examiner's con..<;ideration of Grundy is respectfully
Applicant respectfully submits that Claims 1-21, 25, 26 and 30 of the present
application is patentably distinguished over Grundy for the foHowing reasons,
The key to the present invention as claimed in Claim I, for example, is that a "licensee
unique ID" generated by a local licensee unique IU generating [)leans has matched a licensee
unique 10 generated by a remote licensee unique 10 generating means (see the last four lines
of Claim 1 a..'l filed). This matching requirement reflects the fact that the undeTlying algoriduns
which prOCeSS identifYing iniOmwtion illput into both the local
uIliqw: ID generating
means flnd the remote licensee unique TD generating means are the same and that both TO
generating means rely upon the same inl
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