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Docket No.: 418278883US1 (PATENT)

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

In re Reexamination Application of:

Patent No. 6,725,281

Application No.: 90/011,541 Confirmation No.: 5471

Filed: March 7, 2011 Art Unit: 3992

For: SYNCHRONIZATION OF CONTROLLED Examiner: R. S. Desai DEVICE STATE TABLE AND EVENTING IN DATA-DRIVEN REMOTE DEVICE CONTROL MODEL

RESPONSE TO OFFICE ACTION IN EX PARTE REEXAMINATION

Commissioner for Patents P.O. Box 1450 Alexandria, VA 22313-1450

Sir:

INTRODUCTORY COMMENTS

Patent owner acknowledges receipt of the Office Action dated August 16, 2011.

Amendments to the Claims are reflected in the listing of claims which begins on

page 2 of this paper.

Remarks/Arguments begin on page 11 of this paper.

41827-8883.US01/LEGAL21648953.3

Comcast, Exhibit-11211

Application No.: 90/011,541 Docket No.: 418278883US1

AMENDMENTS TO THE CLAIMS

1. (Original) A distributed computing network having at least one computing

device, the distributed computing network comprising:

a controlled computing device;

a state table maintained by the controlled computing device and representing an

operational state of the controlled computing device;

a user controller device having user input/output capability for presenting a user

perceptible device control interface for remote user interaction with the

controlled computing device to effect a change in the operational state of

the controlled computing device represented in the state table;

a user control point module in the user controller device operating to obtain a

copy of the state table of the user controller device and subscribe to

change notifications of the state table; and

an event source module in the controlled computing device operating according

to an eventing model to distribute the change notifications to any

subscribing user controller device upon a change to the state table

representing the operational state of the controlled computing device,

wherein the change notifications represent the respective change in the

state table, so as to thereby synchronize the user perceptible device

control interface with the changed operational state among said any

subscribing user controller device.

2. (Original) The distributed computing network of claim 1 further

comprising:

the state table having a plurality of entries, wherein each entry of the state table

comprises at least a variable identifier, a type and a current value;

at least one entry of the state table being of a type of data buffer, and containing

a file as its current value;

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whereby a change to the current value of said at least one entry effects a file

transfer from the controlled device to said any subscribing user control

device.

3. (Original) The distributed computing network of claim 1 wherein the

controlled computing device is an embedded computing device.

4. (Original) The distributed computing network of claim 1, further

comprising a computer-readable medium controlled computing device having encoded

thereon the state table representing the operational state of the controlled computing

device, the state table comprising:

a plurality of entries, each entry comprising:

a variable identifier; and

a current value.

20. (Amended) A peer networking state eventing and control protocol method

for effecting state-concurrent multi-master control of a controlled computing device by a

plurality of control point computing devices communicating on a data communications

network, the data communications network having the controlled computing device, a

state table maintained by the controlled computing device and representing an

operational state of the controlled computing device, a control point computing device

having user input/output capability for presenting a user perceptible device control

interface for remote user interaction with the controlled computing device and

communicating with the controlled computing device via a device control protocol to

effect remote operational control of the controlled computing device, a user control point

module in the control point computing device operating to obtain a copy of the state

table of the control point computing device and subscribe to change notifications of the

state table, and an event source module operating according to an eventing model to

distribute the change notifications to any subscribing control point computing device

upon a change to the operational state of the controlled computing device, so as to

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Application No.: 90/011 ,541 Docket No.: 418278883US1

thereby synchronize the user perceptible device control interface with the changed

operational state among said any subscribing control point computing device, the

method comprising:

from a plurality of the control point computing devices, receiving state eventing

subscription requests;

responsive to the state eventing subscription requests, registering subscriptions

of the respective control point computing devices to state events from the

controlled computing device;

communicating state events having information descriptive of a state of the

controlled computing device to the respective control point computing

devices of the registered subscriptions;

receiving a control command from a control point computing device instructing

the controlled computing device to perform a specified operation affecting

the state of the controlled computing device;

responsive to the control command, performing the specified operation; and

communicating further state events having information descriptive of the state of

the controlled computing device after the specified operation is performed

to the respective control point computing devices of the registered

subscriptions, whereby the plurality of control point computing devices

having registered subscriptions can maintain concurrent storage of data

representing the state of the controlled computing device.

23. (New) The distributed computing network of claim 1, the controlled

computing device storing presentation data defining a presentation of the user

perceptible device control interface.


computing device being further configured to transfer the presentation data defining the

presentation of the user perceptible device control interface to the user controller

device.

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25. (New) The distributed computing network of claim 23, the user controller

device further operating to receive the presentation data defining the presentation of the

user perceptible device control interface from the controlled computing device and

present the user perceptible device control interface.

26. (New) The distributed computing network of claim 25 wherein the user

controller device is a mobile phone.


controller device is a set-top box.


controller device is a handheld computer.

29. (New) The distributed computing network of claim 23 wherein the state

table maintained by the controlled computing device represents a current electrical state

of the controlled computing device.


table maintained by the controlled computing device represents a current mechanical

state of the controlled computing device.


table maintained by the controlled computing device represents a current logical state of

the controlled computing device.

32. (New) The distributed computing network of claim 1, the user control point

module in the user controller device further operating to unsubscribe to change

notifications of the state table.

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computing device being configured to send a copy of the state table maintained by the

controlled computing device to the user control point module in the user controller

device in response to receiving a subscribe message from the user control point

module.


control point module is configured to subscribe to change notifications of the state table

by sending to the controlled computing device a subscribe message specifying a

timeout duration and wherein the controlled computing device is configured to remove

the subscription of the user control point module in response to determining that a re

subscribe message has not been received from the user control point module for at

least the specified timeout duration.


control point module is configured to form an unsubscribe message and unsubscribe to

change notifications of the state table by sending the unsubscribe message to the

controlled computing device.

36. (New) The distributed computing network of claim 1 wherein the

controlled computing device is a cell phone.


controlled computing device is an audio and video recorder.


controlled computing device is an audio or video playback device.


controlled computing device is a set-top box.

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table represents a tuner channel selection.


table represents an audio decoding format.


table represents a video decoding format.


controlled computing device is a game console.


controlled computing device is an environment control device.


controller device is a mobile phone.


controller device is a set-top box.


controller device is a handheld computer.

48. (New) The peer networking state eventing and control protocol method of

claim 20, further comprising:

storing presentation data defining a presentation of the user perceptible device

control interface; and

transferring the presentation data defining the presentation of the user

perceptible device control interface to a control point computing device.

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claim 48 wherein at least one of the plurality of control point computing devices is a

mobile phone.


claim 48 wherein at least one of the plurality of control point computing devices is a set

top box.



handheld computer .

. 52. (New) The peer networking state eventing and control protocol method of


storing in the state table maintained by the controlled computing device a

representation of a current electrical state of the controlled computing

device.




representation of a current mechanical state of the controlled computing

device.




representation of a current logical state of the controlled computing

device.

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from a plurality of the control point computing devices, receiving state eventing

unsubscribe requests.



sending a copy of the state table maintained by the controlled computing device

to a first user control point module in response to receiving a subscribe

message from the first user control point module.



receiving, from a first user control point module, a subscribe message specifying

a timeout duration; and

removing the subscription of the first user control point module in response to

determining that a re-subscribe message has not been received from the

first user control point module for at least the specified timeout duration.


claim 48 wherein the controlled computing device is a cell phone.


claim 48 wherein the controlled computing device is an audio and video recorder.


claim 48 wherein the controlled computing device is an audio or video playback device.


claim 48 wherein the controlled computing device is a set-top box.

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table represents a tuner channel selection of the set-top box.


table represents an audio decoding format of the set-top box.


table represents a video decoding format of the set-top box.


claim 48 wherein the controlled computing device is a game console.


claim 48 wherein the controlled computing device is an environment control device.



mobile phone.


claim 48 wherein at least one of the plurality of control point computing devices is a set

top box.



handheld computer.

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REMARKS

I. Introduction

Claims 1-4 and 20 of U.S. Patent No. 6,725,281 ("the '281 patent") were

considered in the Non-Final Office Action ("the Office Action") mailed on August 16,

2011. The third party requester did not request reexamination of the remaining claims.

Accordingly, claims 5-19, 21, and 22 are notsubjectto reexamination. 1

The patent owner herein amends claim 20, presents new claims 23-69, and does

not cancel any claims. Accordingly, claims 1-4, 20, and 23-69 are currently under

consideration.

The Office Action rejects claims 1, 3, 4, and 20 under 35 U.S.C. § 102(b) over

U.S. Patent No. 6,404,743 to Meandzija ("Meandzija"), rejects claims 1, 3, 4, and 20

under 35 U.S.C. § 102(b) over U.S. Patent No. 6, 167,433 to Maples et al. ("Maples"),

rejects claims 1, 3, 4, and 20 under 35 U.S.C. § 103(a) over the combination of U.S.

Patent No. 6,389,464 to Krishnamurthy et al. ("Krishnamurthy") and Meandzija, and

rejects claims 1-4 and 20 under 35 U.S.C. § 103(a) over the combination of U.S. Patent

No. 5,655,081 to Bonnell et al. ("Bonnell") and Maples. The patent owner respectfully

traverses these rejections and, at least for the reasons set forth below, submits that

each of the claims under consideration is patentable over the applied references, alone

or in combination.

II. Current Status of Litigation Involving the '281 patent

The '281 patent is currently the subject of litigation between Microsoft

Corporation and Tivo Inc. The case is captioned Case No. 5:1 O-cv-00240-LHK,

Microsoft Corporation v. Tivo Inc. Proceedings in the litigation have been stayed

pending completion of re-examination.

1 Silence regarding a position taken, or argument made, by the Examiner does not indicate any acquiescence to that position or argument. Furthermore, arguments made with respect to any particular claim or claims apply to only those claims and not to any other claims or patents/applications unless specifically noted herein.

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Ill. Claim Amendments

Support for the clarifying amendments to claim 20 can be found in the '281 patent

including, but not limited to, e.g., col. 1, line 66 to col. 2, line 16 and col. 43, lines 40-59.

IV. New Claims

Support for the newly added claims can be found in the '281 patent including, but

not limited to, the following portions:

claims 23-25 and 48: see, e.g., '281 patent at col. 2, lines 1-7 and col. 5, line 39

to col. 6, line 9,

claims 26-28, 45-47, 49-51, and 67-69: see, e.g., '281 patent at col. 6, lines 43-

44,

claims 29-31 and 52-54: see, e.g., '281 patent at col. 8, lines 53-56,

claims 32, 35, and 55: see, e.g., '281 patent at col. 38, lines 25-41,

claim 33 and 56: see, e.g., '281 patent at col. 43, lines 40-43,

claim 34 and 57: see, e.g., '281 patent at col. 36, line 55 to col. 37, line 18,

claims 36, 37, 39, 43, 44, 58, 59, 61, 65, and 66: see, e.g., '281 patent at col. 45,

lines 26-47,

claim 38 and 60: see, e.g., '281 patent at col. 6, line 61, and

claims 40-42 and 62-64: see, e.g., '281 patent at col. 13, lines 61-66.

V. Background

During the 1990s, computers were becoming increasingly popular in U.S.

households, growing from 15% of U.S. households in 1989 to 51 % in 2000.

(Newburger, Eric C., Home Computers and Internet Use in the United States: August

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2000, U.S. Census Bureau, p. 1.) By the late 1990s, network and Internet access within

U.S. households was also increasing rapidly, with 18% of U.S. households having

Internet access in 1997 to 41.5% in 2000. (Newburger, p. 1.) Seeing these trends,

personal computer (PC) manufacturers began to "ship PCs with built-in support for

Ethernet, IEEE 1394, radio frequency (RF), power line carrier (PLC), or phone line

connectivity that makes it possible to add home networking without adding wires."

(Christensson, Bengt and Larsson, Olaf, Universal Plug and Play Connects Smart

Devices, WinHEC 99 White Paper, 1999, p. 3.) "Set-top boxes, networked

entertainment appliances, and other smart devices [were also] evolving with the growth

of the Internet and improved bandwidth availability to the home." (Christensson, p. 3.)

The '281 patent describes an architecture that enables network-connected

devices, such as desktop computers, mobile phones, etc., to discover, connect to, and

control remote network-connected devices, such as VCRs, DVD players, television set

top boxes (STBs), telephones, heating, ventilation, and air conditioning (HVAC)

systems, lighting systems, and so on. Among other things, the disclosed architecture

enables devices (e.g., DVD player, STB, HVAC system, lighting system) to export user

interfaces over a network so that the devices can be controlled from other devices. For

example, a· representation of "a controlled device's physical control panel (e.g., the

buttons, knobs and display of an audio/video equipment's front panel and infrared

remote) [may be] remoted to other user interface capable control devices." ('281 patent,

1 :61-65.) These user controller devices enable users to interact with and control the

controlled devices through a user interface.

In some embodiments, each controlled device maintains a state table

representing an operational state. ('281 patent, 1 :67-2:1.) User controller devices

obtain copies of the controlled device's state table over a network, for example, and

subscribe to notifications of changes to the state table. ('281 patent, Abstract.) In

response to any change to the controlled device's operational state, such as changes

caused by inputs from a user controller device or the controlled device's front panel or

infrared remote, the controlled device notifies subscribing user controller devices of the

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change. ('281 patent, Abstract and 2:7-16.) Each subscribing user controller device

can then update its copy of the state table so that the copies of the state tables of the

user controller devices remain synchronized. ('281 patent, Abstract and 2:7-16). In this

manner, the "user is able to interact appropriately to the actual current state of the

device, e.g., avoiding issuing a 'toggle power on/off' command when the controlled

device" is already in the desired state. ('281 patent, 2:29-32.)

VI. Brief Description of the Applied References

A. Meandzija

Meandzija describes an "enhanced Simple Network Management Protocol

(SNMP) management system for telecommunications networks." (Meandzija, Abstract).

Meandzija's "invention enables the use of the TMN X.700 techniques in SNMP

management systems through a new mapping of the X.700 information model onto the

SNMP information model." (Meandzija, 4:35-41.) Meandzija employs an "SNMP

management station" in communication with "SNMP management agents" that support

access to managed resources, such as hosts, bridges, routers, and hubs, represented

by "managed objects referred to as the MIB." (Meandzija, 10:4-10.) Each MIB or

"Management Information Base" is a component of the SNMP framework as defined by

"RFC 1213." (Meandzija, 2:45-55.) The SNMP management station monitors

resources by retrieving and storing values of MIB objects from the agents and can also

cause an action to occur at an agent or change its configuration settings by modifying

these values. (Meandzija, 10:1-19.)

In addition to the SNMP-based MIB stored at each agent, Meandzjia also

describes an ITU-T X.731-based "state information module" stored at the SNMP

management station. (Meandzija, Figure 2 and 11 :26-28.) The station's "state

information module" represents "the management state of agents across a network or

internet." (Meandzija, 11:19-21.) In other words, the state information includes state

information for the agent itself, such as "a management state, an administrative state,

an operational state, a user state," and so on. (Meandzjia, 11 :31-37.) Several of these

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states, and their values/transitions, are "defined in the ITU-T X.731 standard."

(Meandzjia, 11 :31-37 and 12:7-13:26.)

Meandzija's management stations define event information, including pre

conditions for generating an event, and communicate the event information to

management agents. When the pre-conditions are met, an event is generated at the

agent and the agent sends a notification regarding the event to the management

station. (Meandzija, 4:55-64.) In this manner, "X-700-style alarm and event

surveillance, and event reporting" is enabled "in a way that is consistent with the SNMP

management paradigm." (Meandzija, 4:38-44.)

B. Krishnamurthy

Krishnamurthy describes a "network management system" comprising at least

one site server connected to manageable devices. (Krishnamurthy, 5:48-67.) The site

server includes an SNMP agent and a set of managed objects or variables, in the form

of an MIB, and provides web pages that guide users to enter configuration information

"to associate a particular device to be managed from the site server 12 to a MIB table in

a MIB." (Krishnamurthy, Figure 3, 2:34-35, and 6:36-44.) By connecting to the site

server, users can configure "any of the MIB variables of a managed device" through a

web interface provided by the site server. (Krishnamurthy, Figure 7 and 11 :24-30.) In

this manner, the site server provides a portal through which users can manage

managed devices.

C. Maples

Maples describes a "synthetic multi-dimensional user oriented environment,"

referred to as "MUSE," and allowing a "group of users to explore, navigate, manipulate

and examine application data in" such an environment. (Maples, 1 :28-31, Abstract.)

Maples' system enables individuals located in different, remote locations can interact

within a shared "virtual space." (Maples, 2:61-66.)

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Maples employs a number of "MUSE" systems, each of which stores local state

and parameter tables that "contain control state and parameter of the local MUSE

system." (Maples, 7:52-54.) Maples' state and parameters tables represent state and

parameters of a synthetic or virtual environment. "Parameters may include information

identifying objects within the virtual environment, while state information may include the

orientation of the object, its translation in space, or any other necessary control state to

accomplish the desired functionality of the application 18 or the MUSE system."

(Maples, 7:54-59.) Additional examples of information that may be stored in Maples'

parameter and state tables include "user position, application scenario time, application

environment scale, application magnification factor, user field of view, lighting control,

the generation of teleportion markers, application object size and placement, or any

other application state." (Maples, 18: 1-5.)

In addition to the local state and parameter tables, each MUSE system includes

a "shared memory" storing state and parameters tables for remote MUSE systems so

that the current state of each individual is known by every user connected in the shared

environment. (Maples, Figure 10 and 11 :8-12.) Each MUSE system "transmits state

values and parameter information only when the state values and parameters

information are changed." (Maples, 15:16-19.) "Each time such information is

changed, it is sent to each of the shared environments" so that the state and parameter

tables of the remote MUSE systems remain synchronized with the local version.

(Maples, 15: 19-24.) Using the tables stored in the shared memory, the local user can

elect to allow a remote user to control various parameters of the local MUSE

environment. For example, "if the local user 30 would like the perspective of the shared

user 2, the local user requests shared user 2 control of the point of view, and the shared

control table 114 provides the information defining this point of view [from the shared

memory] to the application state table and application parameter table." (Maples,

16:31-48.)

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Application No.: 90/011,541

D. Bonnell

Docket No.: 418278883US1

Bonnell describes techniques for "monitoring and managing applications and

other resources in a computer network." (Bonnell, 6:56-57.) Bonnell's techniques

include using "network management computer systems [that] act as consoles for

monitoring and managing resources present on server computer systems in the

network." (Bonnell, 6:64-67.) Bonnell employs "agent software systems" installed on

server computer systems to "carr[y] out tasks on the computer system in which it is

installed such as discovering which resources and applications are present,"

"monitoring particular aspects of the resources and applications present," and

"executing recovery actions automatically." (Bonnell, 7:2-8.) The agent software

systems include a number of "event catalogs" for storing historical information about

events that have occurred. (Bonnell, 10:11-38.)

VII. The Jones Declaration

The Jones declaration provides a general description of Dr. Jones' interpretation

of the applied references. Dr. Jones makes several assertions regarding the applied

references but does not support these assertions with references to the applied

references. Patent owner does not agree with Dr. Jones' interpretation of the applied

references and believes that at least some of Dr. Jones' assertions are incorrect. For

example, Dr. Jones asserts that "client devices in [Maples'] MUSE environment can be

fully functional standalone system$ such as printers, routers, and hubs, or embedded

devices with basic memory and storage systems such as NIC cards" and that the "state

table contains updated information regarding the respective client devices." (Jones

Declaration, 1f 6.) However, Dr. Jones does not point to any portion of Maples that

describes a state table containing updated information regarding such "client devices."

Rather, Maples' state and parameters tables represent state and parameters of a

synthetic or virtual environment. (Maples, 7:54-59 and 18:1-5.) As another example,

the Jones declaration asserts that Meandzija's management station includes an "MIB

database" containing "a copy of the MIB information (e.g., state table) of the agent

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station." (Jones Declaration, 1f 9.) However, Dr. Jones does not point to any portion of

Meandzija that describes an MIB database containing a "copy" of any state table of the

agent station. Rather, Meandzija describes a management station that receives values

from MIB objects and stores information extracted from MIBs in a database.

(Meandzija, 10:1-16.) Meandzija provides no indication that this "database" is a "copy"

of any MIB or state table or that information retrieved from any MIB constitutes a copy of

the MIB.

VIII. Rejection under 35 U.S.C. § 102(b) over Meandzija

A. Meandzija does not Qualify as Prior Art under 35 U.S.C. § 102(b)

Patent owner submits that Meandzija does not qualify as prior art to the '281

patent under 35 U.S.C. § 102(b). According to the United States Code,

"[a] person shall be entitled to a patent unless-

(b) the invention was patented or described in a printed publication in this or a foreign country or in public use or on sale in this country, more than one year prior to the date of the application for patent in the United States."

(35 U.S.C. § 102.) Meandzija, which claims priority to U.S. Provisional Application

No. 60/064, 178, was filed on May 11, 1998 and issued on June 11, 2002. U.S. Patent

Publication No. 2002/0085571, which corresponds to Meandzija, was published on

July 4, 2002. The '281 patent, however, was filed on November 2, 1999. Thus,

Meandzija was not patented or described in a printed publication in this or a foreign

country more than one year prior to the date of the application for patent in the United

States (November 2, 1999). Moreover, the Office Action does not establish that the

disclosure of Meandzjia was in public use or on sale in this country more than one year

prior to November 2, 1999. Accordingly, Meandzija does not qualify as prior art under

35 U.S.C. § 102(b). For at least this reason, patent owner respectfully requests that the

Examiner withdraw this rejection of claims 1, 3, 4, and 20.

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Notwithstanding the improper rejection of the pending claims under 35 U.S.C.

§ 102(b), patent owner would like to make the following comments regarding differences

between the pending claims and Meandzija.

8. Meandzija does not disclose "a user control point module in the user controller device operating to obtain a copy of the state table," as claim 1 recites

Independent claim 1 recites, inter alia, "a user control point module in the user

controller device operating to obtain a copy of the state table of the user controller

device." The Office Action relies on Meandzija at 9:50-54, 10:37-40, 11 :31-35, 11 :48-

55, Figure 2, and Figure 4 as disclosing this feature. (Office Action, August 16, 2011,

p. 8.) According to the Office Action, Meandzija's "MIB" corresponds to the recited

"state table." (Office Action, August 16, 2011, p. 6.) Even assuming, for the sake of

argument, that Meandzija's "MIB" corresponds to "a state table maintained by the

controlled computing device and representing an operational state of the controlled

computing device," which patent owner does not concede, the relied-upon portions of

Meandzija do not disclose a user control point operating to obtain a QQQY of the MIB.

The relied-upon portions of Meandzija describe two separate data structures

stored by different entities: the SNMP-based MIB, stored by an SNMP agent, and an

ITU-T X.731-based "state information module" stored at an "SNMP management

station." (See Meandzija, Figure 2.) The Office Action does not point to any portion of

Meandzija that discloses that Meandzija's state information module is a "copy" of

Meandzija's MIB. Meandzija's state information module includes a "management state"

that "represents the instantaneous condition of availability and operability of the

associated agent resource from the point of view of management" and further includes

"a number of states and status functions, including a management state, an

administrative state, an operational state, a usage state, a procedural status, an alarm

status, an availability status, control status, a standby status, and an unknown status."

(Meandzija, 11 :31-35 and Figure 4.) Meandzija's MIB, in contrast, comprises

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representations of managed objects, each representing a managed resource.

Meandzija does not disclose that the state information module is a "copy" of the MIB.

Moreover, the Office Action's reliance on portions of Meandzija that describe a

processor of an SNMP agent communicating with both the SNMP management station

and the MIB (Meandzija, 9:50-54 and 10:37-40), does not cure these deficiencies

because Meandzija does not disclose that these communications including

communicating a "copy" of the MIB to the management station.

The Request for Ex Parte Reexamination and the Jones declaration similarly

conflate Meandzija's state information module and MIB and do not point to any portion

of Meandzija that describes that a copy of the MIB is obtained or that the state

information module is a copy of the MIB. The Request for Ex Parte Reexamination, for

example, asserts that the "management system of Meandzija includes a 'database of

information extracted from the MIBs of all the managed entities in the network."'

(Request for Ex Parte Reexamination, March 7, 2011, p. 12 (citing Meandzija, 10:1-2)

(emphasis added by Request for Ex Parte Reexamination)). However, the Request for

Ex Parte Reexamination fails to point to any portion of Meandzija which indicates that

the database of Meandzija's management system includes all of the information of

Meandzija's MIB as opposed to selected portions of the MIB. In other words, the

database of Meandzija's management system is not a "copy" of the MIB.

As another example, the Jones declaration asserts that once certain criteria are

met "the agent station sends an SNMP trap message (e.g., event notification) to the

management station, updating a MIB database at the management station containing a

copy of the MIB information (e.g., state table) of the agent state (e.g., monitored

device). (Jones' Declaration, ,-r 9.) The state information module can thus store the

updated change in states at the managed station." (Jones Declaration, ,-r 9.) The Jones

declaration, however, fails to identify any portion of Meandzija that supports its assertion

that Meandzija's management station maintains an "MIB database" that is a .QQQY of the

MIB maintained by the "agent station." Furthermore, even if, as the Jones declaration

41827-8883.US01 /LEGAL21648953.3 20

20


asserts, the "state information module can thus store the updated change in states at

the managed station," the Jones declaration fails to point to, and patent owner is unable

to find, any portion of Meandzija disclosing that the state information is a "copy" of the

MIB.

For at least these reasons, the relied-upon portions of Meandzija do not

identically disclose "a user control point module in the user controller device operating

to obtain a copy of the state table" as claim 1 recites. Patent owner respectfully

requests that the Examiner reconsider and withdraw this rejection of claim 1 and its

dependent claims 3 and 4.

C. Meandzija does not disclose "a user control point module in the control point computing device operating to obtain a copy of the state table," as claim 20 recites

Independent claim 20 now recites, inter alia, "a user control point module in the

control point computing device operating to obtain a copy of the state table of the

control point computing device." This feature is similar to the feature discussed above

with respect to claim 1, which the Office Action relies on Meandzija at 9:50-54, 10:37-

40, 11 :31-35, 11 :48-55, Figure 2, and Figure 4 as disclosing. (Office Action, August 16,

2011, p. 8.) As discussed above, the relied-upon portions of Meandzija describe two

separate data structures stored by different entities: the SNMP-based MIB, stored by

an SNMP agent, and an ITU-T X.731-based "state information module" stored at an

"SNMP management station." (See Meandzija, Figure 2.) The Office Action does not

establish that the state information module is a "copy" of the MIB or that the SNMP

management station operates to "obtain a copy" of the MIB. For at least these reasons,

the relied-upon portions of Meandzija do not identically disclose "a user control point

module in the control point computing device operating to obtain a copy of the state

table of the control point computing device," as claim 20 now recites. For at least this

reason, patent owner respectfully requests that the Examiner reconsider and withdraw

this rejection of claim 20.

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21


D. Meandzija does not disclose "a state table maintained by the controlled computing device and representing an operational state of the controlled computing device," as claims 1 and 20 recite

Independent claims 1 and 20 recite, inter alia, "a state table maintained by the


computing device." The Office Action relies on Meandzija at 10:3-10 as disclosing this

feature, pointing specifically to Meandzija's "agent" as corresponding to the recited

"controlled computing device" and Meandzija's "MIB" as corresponding to the recited

"state table." (Office Action, August 16, 2011, p. 6.) As discussed above, Meandzija's

MIB comprises "managed objects" each representing a "managed resource."

(Meandzija, 10:3-10.) The information stored in Meandzija's MIB pertains to those

resources managed by the agent, not the agent itself. Thus, Meandzija's MIB does not

represent an operational state of Meandzija's SNMP agent. Accordingly, Meandzija's

MIB does not maintain information representing an operational state of Meandzija's

agent which, according to the Office Action, corresponds to the recited "controlled

computing device." (Office Action, August 16, 2011, p. 6.) Accordingly, the relied-upon

portions of Meandzija do not identically disclose "a state table maintained by the


computing," as claims 1 and 20 recite. For at least this reason, patent owner

respectfully requests that the Examiner withdraw this rejection of independent claims 1

and 20 and dependent claims 3 and 4, which depend from claim 1 .

E. Meandzija does not disclose "the state table comprising: a plurality of entries, each entry comprising: a variable identifier; and a current value," as claim 4 recites

Dependent claim 4 recites, inter alia, "the state table comprising: a plurality of

entries, each entry comprising: a variable identifier; and a current value." The Office

Action relies on Meandzija at 2:66-3:9 as disclosing these features, pointing specifically

to Meandzija's MIB. (Office Action, August 16, 2011, p. 11.) The MIB defines objects

where "each object type is named by an object identifier, an administratively assigned

name" and "[t]he object type together with an object instance serves to uniquely

41827-8883.US01 /LEGAL21648953.3 22

22


identify a specific instantiation of the object." (Office Action, August 16, 2011, p. 11

(quoting Meandzija, 3:3-7) (emphasis added by Office Action).) Patent owner

respectfully disagrees that Meandzija's object identifier or object instance are variable

identifiers. Although different objects may have different object identifiers and each

instance of an object may correspond to different instantiations of an object, for a

specific instantiation of an object, neither the value of the object identifier nor the object

instance value change. In other words, the object identifier and the object instance are

not "variable identifiers." If either the object identifier value or the object instance value

could change for an instantiated object, the object type (object identifier value) and

object instance would not serve to uniquely identify a specific instantiation, which is in

contrast to Meandzija's description. Accordingly, the relied-upon portions of Meandzija

do not identically disclose a "state table comprising: a plurality of entries, each entry

comprising: a variable identifier; and a current value," as claim 4 recites. For at least

this reason, patent owner respectfully requests that the Examiner reconsider and

withdraw this rejection of claim 4.

IX. Rejection under 35 U.S.C. § 103(a) over Meandzija and Krishnamurthy

A. The combination of Meandzija and Krishnamurthy neither describes nor suggests "a user control point module in the user controller device operating to obtain a copy of the state table," as claim 1 recites

Independent claim 1 recites, inter alia, "a user control point module in the user

controller device operating to obtain a copy of the state table of the user controller

device." As the Office Action points out, Krishnamurthy does not disclose this feature.

(Office Action, August 16, 2011, p. 35.) The Office Action relies on Meandzija at 9:50-

54, 10:37-40, 11 :31-35, 11 :48-55, and Figure 4 as disclosing this feature. (Office

Action, August 16, 2011, pp. 35-36.) As discussed above, Meandzija does not disclose

"a user control point module in the user controller device operating to obtain a copy of

the state table of the user controller device." Rather, the relied-upon portions of

Meandzija describe two separate data structures stored by different entities: the SNMP-

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23


based MIB, stored by an SNMP agent, and an ITU-T X.731-based "state information

module" stored at an "SNMP management station," neither of which is a "copy" of the

other. (See Meandzija, Figure 2.) For at least this reason, the relied-upon portions of

the applied references neither describe nor suggest "a user control point module ...

operating to obtain a copy of the state table" as claim 1 recites. Patent owner

respectfully requests that the Examiner reconsider and withdraw this rejection of claim 1

and its dependent claims 3 and 4.

B. The combination of Meandzija and Krishnamurthy neither describes nor suggests "a user control point module in the control point computing device operating to obtain a copy of the state table," as claim 20 recites

Independent claim 20 now recites, inter alia, "a user control point module in the

control point computing device operating to obtain a copy of the state table of the

control point computing device." This feature is similar to the feature discussed above

with respect to claim 1, which the Office Action relies on Meandzija at 9:50-54, 10:37-

40, 11 :31-35, 11 :48-55, and Figure 4 as disclosing this feature. (Office Action,

August 16, 2011, pp. 35-36.) As discussed above, Meandzija does not disclose this

feature. For at least reasons similar to those discussed above with respect to claim 1,

patent owner respectfully requests that the Examiner reconsider and withdraw this

rejection of claim 20.

C. The combination of Meandzija and Krishnamurthy neither describes nor suggests "a state table maintained by the controlled computing device and representing an operational state of the controlled computing device," as claims 1 and 20 recite



computing device." The Office Action relies on Krishnamurthy at 4:44-47, 6:36-44, and

6:55-65 as disclosing this feature, pointing specifically to Krishnamurthy's "MIB" as

corresponding to the recited "state table" and Krishnamurthy's "site server" as

corresponding to the recited "controlled computing device." (Office Action, August 16,

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24


2011, pp. 33-34). The relied-upon portions of Krishnamurthy describe 1) MIS files,

2) configuration data "used in connection with MIS files," and 3) guiding "a user to enter

configuration information to associate a particular device to be managed from the site

server 12 to a MIS table." None of the relied-upon portions of Krishnamurthy, however,

suggest that Krishnamurthy's MIS represents an operational state of Krishnamurthy's

site server. Rather, information in the MIS is associated with "a particular device to be

managed from the site server." (Krishnamurthy, 6:42-43 (emphasis added).)

Furthermore, the Office Action does not point to any portion of Krishnamurthy that

describes the managed devices maintaining an MIS. The relied-upon portions of

Krishnamurthy neither describe nor suggest "a state table maintained by the controlled

computing device and representing an operational state of the controlled computing

device," as claims 1 and 20 recite. As discussed above, Meandzija does not cure this

deficiency. Accordingly, patent owner respectfully requests that the Examiner withdraw

this rejection of independent claims 1 and 20 and dependent claims 3 and 4, which

depend from claim 1.

D. The combination of Meandzija and Krishnamurthy neither describes nor suggests "wherein the controlled computing device is an embedded computing device," as claim 3 recites

Dependent claim 3 recites, inter alia, "wherein the controlled computing device is

an embedded computing device." The Office Action relies on Krishnamurthy at Figure 3

and 6:28-39 as disclosing this feature. (Office Action, August 16, 2011, p. 38.) Patent

owner respectfully disagrees. According to the Office Action, "Krishnamurthy discloses

a controlled computing device as the site server." (Office Action, August 16, 2011, p. 33

(emphasis added).) The relied-upon portions of Krishnamurthy describe a site server

having a "modem" and "Ethernet 10-SaseT board" and operating "using an I SA-Sus

architecture." These elements, however, do not suggest that Krishnamurthy's site

server itself is an "embedded device." Even assuming, for the sake of argument, that

Krishnamurthy's modem, Ethernet board, and bus architecture constitute embedded

devices (which patent owner does not concede), Krishnamurthy's site server is not an

embedded device, as the Office Action asserts. Accordingly, the relied-upon portions of

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25


the applied references neither describe nor a suggest "wherein the controlled computing

device is an embedded computing device," as claim 3 recites. Patent owner

respectfully requests that the Examiner reconsider and withdraw this rejection of claim

3.

X. Rejection under 35 U.S.C. § 102(b) over Maples

A. Maples does not disclose "a user control point module ... operating to ... subscribe to change notifications of the state table" as claims 1 and 20 recite

Independent claims 1 and 20 recite, inter alia, "a user control point module ...

operating to ... subscribe to change notifications of the state table." The Office Action

relies on Maples at 18:6-30 as disclosing this feature. (Office Action, August 16, 2011,

pp. 23-24 and 28-29.) Patent owner respectfully disagrees that the relied-upon portion

of Maples discloses this feature. Maples at 18:6-30 describes allowing different users to

exert control over different aspects of Maples' synthetic environment imaging system

through Maples' "shared control table." For example, "if the local user 30 would like the

perspective of the shared user 2, the local user requests shared user 2 control of the

point of view, and the shared control table 114 provides the information defining this

point of view to the application state table and application parameter table." (Maples,

16:43-48.) However, Maples' distributed "remote MUSE systems" do not subscribe to

change notifications of Maples' state and parameter tables. Rather, each system

"transmits state values and parameter information only when the state values and

parameter information are changed in value" and "[e]ach time such information is

changed, it is sent to each of the shared environments." (Maples, 15:16-21 (emphasis

added).) Because the state value and parameter information changes are automatically

distributed to the various systems, there is no reason for Maples' systems to "subscribe

to change notifications of the state table" as recited and Maples does not describing a

system subscribing to any change notifications.

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26


The Office Action's assertion that Maples at 18:6-30 "teaches that subscription

may be optionally selected by denoting whether the local user is in control of a particular

parameter of if (sic) the state is shared between users" is misplaced. (Office Action,

August 16, 2011, pp. 23-24.) Although a local user may select remote or local control

over a particular parameter of the local system, the local system receives state value

and parameter information changes from the remote systems regardless of the local

user's parameter control selections. For example, if the local user would like the

perspective of the shared user 2, the local system is still notified of any changes to the

perspective information of other shared users. If the local user decides to switch to the

perspective of shared user 1, the local system is. still notified of any changes to the

perspective information of shared user 2. Thus, the local user's selection of remote or

local control over a particular parameter does not affect the local system's receipt of

change notifications of that parameter from remote systems. Accordingly, a local

system need not "subscribe" to change notifications and the relied-upon portions of

Maples do not disclose "a user control point module in the user controller device

operating to ... subscribe to change notifications of the state table," as claims 1 and 20

recite. For at least this reason, patent owner respectfully requests that the Examiner

reconsider and withdraw this rejection of independent claims 1 and 20 and dependent

claims 3 and 4, which depend from claim 1.

B. Maples does not disclose "a state table maintained by the controlled computing device and representing an operational state of the controlled computing device," as claims 1 and 20 recite



computing device." The Office Action relies on Maples at 7:47-59 as disclosing this

feature. (Office Action, August 16, 2011, pp. 21-22.) Patent owner respectfully

disagrees that Maples discloses a state table representing an operational state of a

controlled computing device. Maples at 7 :4 7 -59 describes "state and parameter

tables 120, 122 which are a representation of all control states and parameters needed

to control [Maples' MUSE] application" and "contain each control state and parameter

41827-8883.US01 /LEGAL21648953.3 27

27


for the local MUSE system." Maples' state and parameter tables, however, do not

represent an operational state of a controlled device. Rather, Maples' "[p]arameters

may include information identifying objects within the virtual environment, while state

information may include the orientation of the object, its translation in space, or any

other necessary control state to accomplish the desired functionality of the

application 18 or the MUSE [multi-dimensional user synthetic environment] system 1 O."

(Maples, 7:54-59.) Additional examples of information that may be stored in Maples'

parameter and state tables include "user position, application scenario time, application

environment scale, application magnification factor, user field of view, lighting control,

the generation of teleportion markers, application object size and placement, or any

other application state." (Maples, 18: 1-5.) Thus, Maples' state and parameters tables

represent state and parameters of an application that represents a synthetic or virtual

environment, not "an operational state of [a] controlled computing device," as claims 1

and 20 recite. Although, as the Office Action at p. 21 indicates, "the local multi

dimensional synthetic environment or MUSE system 10 may be implemented with

virtually any general purpose digital computer having multi-processing capabilities and

virtually any input and output devices," Maples' state and parameter tables do not store

"an operational state" of any general purpose digital computer, input, or output device.

For at least these reasons, patent owner respectfully requests that the Examiner

reconsider and withdraw this rejection of independent claims 1 and 20 and dependent

claims 3 and 4, which depend from claim 1.

C. Maples does not disclose "wherein the controlled computing device is an embedded computing device," as claim 3 recites

Dependent claim 3 recites "wherein the controlled computing device is an

embedded computing device." The Office Action relies on Maples at 5:60-67 as

disclosing this feature. Patent owner respectfully disagrees. According to the Office

Action, the "controlled computing device" corresponds to Maples' "local multi

dimensional synthetic environment or MUSE system 1 O" which "may be implemented

with virtually any general purpose digital computer having multi-processing capabilities

41827-8883.US01/LEGAL21648953.3 28

28


and virtually any input and output devices" and "employs a shared memory to interact

between the user 30 and a selected synthetic environment application." (Office Action,

August 16, 2011, p. 21; Maples 5:60-67.) As is clear form Maples, the local multi

dimensional synthetic environment or MUSE system is a general purpose digital

computer, not an embedded device.

The Jones declaration's assertion that "[c]lient devices in the MUSE environment

can be fully functional computers, standalone systems such as printers, routers, and

hubs, or embedded devices with basic memory and storage systems such as NIC

cards" is not supported by Maples. Maples clearly indicates that "the local multi

dimensional synthetic environment or MUSE system 10 may be implemented with

virtually any general purpose digital computer having multi-processing capabilities and

virtually any input and output devices." (Maples, 5:60-64 (emphasis added).) Although

Maple's system may include input and output devices in addition to "virtually any

general purpose digital computer," these input and output devices do not constitute

Maples' local multi-dimensional synthetic environment or MUSE system. Maples'

MUSE systems, which include a "general purpose digital computer having multi

processing capabilities," are not embedded devices. Maples does not identically

disclose a "controlled computing device [that] is an embedded computing device" as

recited. For at least this reason, patent owner respectfully requests that the Examiner

reconsider and withdraw this rejection of claim 3.

XI. Rejection under 35 U.S.C. § 103(a) over Maples and Bonnell

A. The combination of Maples and Bonnell neither describes nor suggests "a user control point module ... operating to ... subscribe to change notifications of the state table" as claims 1 and 20 recite

Independent claims 1 and 20 recite, inter alia, "a user control point module ...

operating to ... subscribe to change notifications of the state table." As the Office

Action points out, Bonnell does not disclose this feature. (Office Action, August 16,

2011, p. 52.). The Office Action relies on Maples at 18:6-30 as disclosing this feature.

41827-8883.US01 /LEGAL21648953.3 29

29


(Office Action, August 16, 2011, p. 53.). As discussed above, the relied-upon portions

of Maples do not disclose this feature. Accordingly, for at least reasons similar to those

discussed above, patent owner respectfully requests that the Examiner reconsider and

withdraw this rejection of claims 1 and 20 and dependent claims 2-4, which depend

from claim 1.

8. The combination of Maples and Bonnell neither describes nor suggests "a user perceptible device control interface for remote user interaction with the controlled computing device to effect a change in the operational state of the controlled computing device represented in the state table," as claim 1 recites

Independent claim 1 recites "a user perceptible device control interface for

remote user interaction with the controlled computing device to effect a change in the

operational state of the controlled computing device represented in the state table." The

Office Action relies on Bonnell at 2:29-51 as disclosing this feature. (Office Action,

August 16, 2011, p. 51.) Patent owner respectfully disagrees that the relied-upon

portion of Bonnell discloses an interface for remote user interaction to effect a change in

the operational state of the controlled computing device represented in the state table.

The relied-upon portions of Bonnell describe "components for implementing [a] manager

software system," which include a graphical user interface "to present visual

representations of objects on the display of [a] network management computer system"

and "coordinate[ ] the representation of pop-up windows for command menus and the

display of requested or monitored data." (Bonnell, 2:29-31.) The graphical user

interface Bonnell describes, however, does not permit remote user interaction to effect a

change in an operational state of a controlled device as recited. Rather, the graphical

user interface of Bonnell permits monitoring of the state or other requested information

of objects present on a computer network, not effecting a change in the state or

information. Thus, even assuming, for the sake of argument, that the user interface can

be "incorporated ... within Bonnell to create a simple and easy method for monitoring

devices from a user perspective," as the Office Action asserts, the incorporation only

permits monitoring of devices, not the ability to "effect a change in the operational state

41827-8883.US01/LEGAL21648953.3 30

30


of [a] controlled computing device," as recited. (Office Action, August 16, 2011, p. 52.)

For at least this reason, patent owner respectfully requests that the Examiner

reconsider and withdraw this rejection of claim 1 and its dependent claims 2-4.

C. The combination of Maples and Bonnell neither describes nor suggests "a user perceptible device control interface for remote user interaction with the controlled computing device and communicating with the controlled computing device via a device control protocol to effect remote operational control of the controlled computing device," as claim 20 recites

Independent claim 20 .recites "a user perceptible device control interface for

remote user interaction with the controlled computing device and communicating with

the controlled computing device via a device control protocol to effect remote

operational control of the controlled computing device." The Office Action relies on

Bonnell at 2:29-51 as disclosing this feature. (Office Action, August 16, 2011, p. 59.)

As discussed above, the relied-upon portions of Bonnell describe a graphical user

interface that permits monitoring of the state or other requested information of objects

present on a computer network, not effecting a change in the state or information.

Thus, even assuming, for the sake of argument, that the user interface can be

"incorporated ... within Bonnell to create a simple and easy method for monitoring

devices from a user perspective," as the Office Action asserts, the incorporation only

permits monitoring of devices, not the ability to "effect a change in the operational state

of [a] controlled computing device," as recited. (Office Action, August 16, 2011, p. 59.)

For at least this reason, patent owner respectfully requests that the Examiner

reconsider and withdraw this rejection of claim 20.

41827-8883.US01/LEGAL21648953.3 31

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D. The combination of Maples and Bonnell neither describes nor suggests "the state table having a plurality of entries, wherein each entry of the state table comprises at least a variable identifier, a type and a current value," "at least one entry of the state table being of a type of data buffer, and containing a file as its current value," or "whereby a change to the current value of said at least one entry effects a file transfer from the controlled device to said any subscribing user control device," as claim 2 recites

Dependent claim 2 recites, inter alia, "the state table having a plurality of entries,

wherein each entry of the state table comprises at least a variable identifier, a type and

a current value." The Office Action relies on Bonnell at 9:61-10:4 and Figure 14 as

disclosing this feature. Patent owner respectfully disagrees that the relied-upon portion

of Bonnell discloses an entry comprising "a type." Bonnell at 9:61-10:4 and Figure 14

describes and illustrates a "data repository" for "storing historical application parameter

values and related information." The data repository includes three fields: "parameter

identification field," "[m]easurement time field," and "[v]alue field." (Bonnell, 9:66-10:5.)

The parameter identification field "contains a unique identifier" that includes an

"associated application name, instance name and parameter name." (9:66-10:2.)

According to the Office Action, the parameter name corresponds to the recited "type."

(Office Action, August 16, 2011, p. 55.) Bonnell's "parameter name," however, is not a

type. Rather, Bonnell's parameter name represents the name of a parameter and is a

portion of a unique identifier for a particular parameter. Bonnell provides no indication

that the name of a parameter is equivalent to that parameter's "type." In other words,

parameters of the same type may have different names and vice versa. Accordingly,

the relied-upon portion of Bonnell neither describes nor suggests a "state table having a

plurality of entries, wherein each entry of the state table comprises at least a variable

identifier, a type and a current value," as claim 2 recites. For at least this reason, patent

owner respectfully requests that the Examiner reconsider and withdraw this rejection of

claim 2.

Dependent claim 2 recites, inter alia, "at least one entry of the state table being of

a type of data buffer, and containing a file as its current value." The Office Action relies

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32


on Bonnell at 5:23-24 and Figure 7 as disclosing this feature. Patent owner respectfully

disagrees that Bonnell describes an entry in a state table containing a file as its current

value. According to Bonnell at 5:23-24, Figure 7 "is a flow diagram showing how [a]

network management system ... was initialized." Figure 7 illustrates a network

management system initialization process that includes "manager software" sending to

an agent a script program, which the Office Action asserts corresponds to the recited

"file." Bonnell's "script program," however, is not stored in an entry of any table, let

alone a state table representing an operational state of a controlled computing device.

In fact, the relied-upon portions of Bonnell do not mention any "state table," let alone a

state table with an entry that is a type of data buffer. Accordingly, the relied-upon

portions of Bonnell neither describe nor suggest a state table having an entry "being of

a type of data buffer, and containing a file as its current value," as claim 2 recites. For

at least this reason, patent owner respectfully requests that the Examiner reconsider

and withdraw this rejection of claim 2.

Dependent claim 2 recites, inter alia, "whereby a change to the current value of

said at least one entry effects a file transfer from the controlled device to said any

subscribing user control device." The Office Action relies on Bonnell at 16:57-59, 8:10-

12, and Figure 8 as disclosing this feature. (Office Action, August 16, 2011, p. 56.) The

relied-upon portions of Bonnell describe receiving and storing "computer script

programs." Bonnell, however, provides no indication that this receiving and storing is an

effect of "a change to the current value of [an] entry [of a state table]," as claim 2

recites. In fact, the relied-upon portions of Bonnell are completely silent as to any "state

table." Bonnell's "receiving" is part of a "procedure for discovering resources" and not a

result of a change to a value of a state table entry. (Bonnell, 8: 18-20.) The relied-upon

portions of Bonnell simply do not describe or suggest "whereby a change to the current

value of said at least one entry effects a file transfer from the controlled device to said

any subscribing user control device." For at least this reason, patent owner respectfully

requests that the Examiner reconsider and withdraw this rejection of claim 2.

41827-8883.US01/LEGAL21648953.3 33

33


E. The combination of Maples and Bonnell neither describes nor suggests "wherein the controlled computing device is an embedded computing device," as claim 3 recites

Dependent claim 3 recites "wherein the controlled computing device is an

embedded computing device." The Office Action relies on Bonnell at 16:61-65 as

disclosing this feature, asserting that Bonnell's "agent system comprises a RAM and a

non-volatile data storage device." (Office Action, August 16, 2011, p. 56.) Although

Bonnell's agent comprises "a RAM" and "non-volatile data storage service," Bonnell's

agent system need not be an "embedded device." Rather, the "agent system" may

constitute a general purpose computing device that is not an embedded device. The

relied-upon portions of Bonnell simply do not describe or suggest a controlled

computing device that "is an embedded computing device," as claim 3 recites. For at

least this reason, patent owner respectfully requests that the Examiner reconsider and

withdraw this rejection of claim 2.

XI I. Conclusion

The patent owner believes no fee is due with this response. However, if a fee is

due, please charge our Deposit Account No. 50-0665, under Order No. 418278883US1

from which the undersigned is authorized to draw.

Dated: September 16, 2011

41827-8883.US01/LEGAL21648953.3

By~~~~~~~~~~-Chun M. Ng

Registration No.: 36,878 PERKINS COIE LLP P.O. Box 1247 Seattle, Washington 98111-1247 (206) 359-8000 (206) 359-7198 (Fax) Attorney for Patent Owner

34

34

Docket No.: 418278883US1 (PATENT)

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

In re Reexamination Application of:

U.S. Patent No. 5,725,281

Application No.: 90/011,541 Confirmation No.: 5471

Filed: March 7, 2011 Art Unit: 3992

For: SYNCHRONIZATION OF CONTROLLED Examiner: RS. Desai DEVICE STATE TABLE AND EVENTING IN DATA-DRIVEN REMOTE DEVICE CONTROL MODEL

Commissioner for Patents P.O. Box 1450 Alexandria, VA 22313-1450

CERTIFICATE OF SERVICE UNDER 37 C.F .R. §§ 1.248(a)(4) AND 1.550(f)

Sir:

I hereby certify that I have delivered copies of the following documents on

September 16, 2011, via first class mail to Greg Gardella, IRELL & MANELLA LLP,

1800 Avenue of the Stars, Suite 900, Los Angeles, CA 90067:

Response to Office Action In Ex Parte Reexamination Certificate of Service

Ar~

41827-8883.USO 1/LEGAL21742625.1 1

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