Lupercal LLC v. CitiBank, N.A.

Western District of Texas, txwd-6:2019-cv-00201

Exhibit PC06

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6 EXHIBIT PC06 6 Attorney Docket No: ADMI.0010001 PATENT IN THE UNITED STATES PATENT AND TRADEMARK OFFICE In re application of Wood et al. Serial No.: 10/961,720 Examiner: Hailu, Tadesse Confirmation No.: 8768 Art Unit: 2173 Filed: 10/8/2004 For: WEB-BASED MEDIA SUBMISSION TOOL Commissioner for Patents Alexandria, VA 22313-14 50 AMENDMENT In response to the Official Action dated January 22, 2010, please amend the above- identified patent application in the following manner. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 2of35 IN THE CLAIMS: Please amend the claims as indicated. A complete set of the claims is included below, as well as the current status of each claim. This listing of claims will replace all prior versions, and listings, of claims in the application. 1-15 (Canceled) 16. (Currently Amended) A computer implemented method of pre-processing digital content in a client device for subsequent electronic publishing, C<?mprising: a. receiving ore-processing parameters from a remote device. said pre- processing parameters including a specification of an amount of digital content, said digital content including one or more of image content, video content, and audio content; b. receiving an identification of a group of one or more items of digital content for transmission, a collective digital content of said group of one or more items of digital content being limited by said received s13eeifieati0A ef saie amel:lRt ef digital eeAteatpre- processing parameters; c. pre-processing said identified group of one or more items of digital content ffi aeeeniaHee ·uith 13revieHsly using said received pre-processing parameters, said 13revi0Hsly received pre-processing parameters eRaaling controlling said client device te-in a placement of said identified group of one or more items of digital content into a specified form in preparation for publication to one or more d<::vices that are remote from a server device and said client device; and 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 3 of35 d. transmitting said pre-processed group of one or more items of digital content to said server device for subsequent publishing to said one or more devices that are remote from said server device and said client device. 17. (Currently Amended) The method of claim 16, wherein said receiving pre-processing parameters a Sf1eeifieatien comprises receiving a specification of a number of items of digital content. 18. (Currently Amended) The method of claim 16, wherein said receiving pre-processing parameters a SfleeifieatieA co,mprises receiving a specification of a maximum number of items of digital content. 19. (Previously Presented) The method of claim 16, wherein said receiving an identification comprises receiving an identification of a plurality of items of digital content. 20. (Previously Presented) The method of claim 16, wherein said receiving an identification comprises receiving a click command at said client device. 21. (Previously Presented) The method of claim 16, wherein said pre-processing comprises reducing a file size or compressing said digital content. 22. (Canceled) 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 4 of35 23. (Currently Amended) A computer implemented method of pre-processing media objects in a local device for subsequent transmission to a remote device, comprising: a. receiving pre-processing parameters from a remote device. said pre- processing parameters including a specification of an amount of media data; b. receiving an identification of a group of one or more media objects for transmission, a collective media data of said group of one or more media objects being limited by said received speeifieatiea ef said am01:1Bt efmeaia Elatapre-processing parameters; c. pre-processing said identified group of one or more media objects m aeeeFElaAee •Nits previ01:1sly using said received pre-processing parameters, wherein said pre- processing comprises changing a file format of said media object; and d. transmitting said pre-processed group of one or more media objects to the remote device. 24. (Canceled) 25. (Previously Presented) The method of claim 16, wherein said pre-processing comprises changing a quality of said digital content. 26. (Currently Amended) A computer implemented method of pre-processing media objects in a local device for subsequent transmission to a remote device, comprising: a. receiving ore-processing parameters from a remote device. said pre- processing parameters including a specification of an amount of media data; 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 5 of35 b. receiving an identification of a group of one or more media objects for transmission, a collective media data of said group of one or more media objects being limited by said received speeifieatieA ef seiel amellAt ef meelia Eietepre-processing parameters; c. pre-processing said identified group of one or more media objects ffi aeeerEiaAee vi'ith previetisly using said received pre-processing parameters, wherein said pre- processing comprises encoding or otherwise converting said media object; and d. transmitting said pre-processed group of one or more media objects to the remote device. 27. (Previously Presented) The method of claim 16, further comprising transmitting identifying information for said pre-processed group of one or more items of digital content. 28. (Currently Amended) A computer implemented method of pre-processing digital content in a client device for subsequent electronic publishing, comprising: a. receiving an identification of digital content, said digital content including one or more of image content, video content, and audio content; b. pre-processing said identified digital content at said client device in accordance with one or more pre-processing parameters that are received from a device separate from said client device availaele te saiel elieAt Eieviee prier te saiel iEieAtifieatien to produce pre-processed digital content, said one or more pre-processing parameters eaa0ling controlling said client device te-in a placement of said digital content into a specified form in 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 6 of35 preparation for publication to one or more devices that are remote from a server device and said client device; c. retrieving information that enables identification of a user, said retrieved information being available to said client device prior to said received identification; and d. transmitting a message from said client device to said server device for subsequent publishing device to said one or more devices that are remote from said server device and said client device, said transmitted message including said pre-processed digital content and said retrieved information. 29. (Previously Presented) The method of claim 28, wherein said pre-processing comprises reducing a file size or compressing said digital content. 30. (Canceled) 31. (Currently Amended) A computer implemented method of pre-processing media objects in a local device for subsequent transmission to a remote device, comprising: a. receiving an identification of a media object for transmission to said remote device; b. pre-processing said identified media object at said local device in accordance with one or more pre-processing parameters that are received from a device separate from said client device availaale ta seie laeal Eleviee ~riar ta said ieeatifieatiaB to produce a pre- processed media object, wherein said pre-processing comprises changing a file format of said media object; 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 7 of3S c. retrieving information that enables identification of a user, said retrieved information being available to said local device prior to said received identification; and d. transmitting a message from said local device to said remote device, said transmitted message including said pre-processed media object and said retrieved information. 32. (Canceled) 33. (Previously Presented) The method of claim 28, wherein said pre-processing comprises changing a quality of said digital content. 34. (Currently Amended) A computer implemented method of pre-processing media objects in a local device for subsequent transmission to a remote device, comprising: a. receiving an identification of a media object for transmission to said remote device; b. pre-processing said identified media object at said local device in accordance with one or more pre-processing parameters that are received from a device separate from · said client device availaale te saie leeal Eleviee prier te saie iEleAtifieatieA to produce a pre- processed media object, wherein said pre-processing comprises encoding or otherwise converting said media object; c. retrieving information that enables identification of a user, said retrieved information being available to said local device prior to said received identification; and 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 8 of35 d. transmitting a message from said local device to said remote device, said transmitted message including said pre-processed media object and said retrieved information. 35. (Previously Presented) The method of claim 28, wherein said pre-processing comprises pre-processing in accordance with one or more pre-processing parameters that have been previously downloaded to said client device. 36. (Previously Presented) The method of claim 28, wherein said pre-processing comprises pre-processing in accordance with one or more pre-processing parameters that have been downloaded to said client device prior to said identification. 37. (Previously Presented) The method of claim 28, wherein said pre-processing comprises pre-processing in accordance with one or more pre-processing parameters that have been stored in memory of said client device prior to said identification. 38. (Previously Presented) The method of claim 28, wherein said retrieving comprises retrieving a user identifier. 39. (Previously Presented) The method of claim 28, wherein said retrieving comprises retrieving a password. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 9 of35 40. (Previously Presented) The method of claim 28, wherein said retrieving comprises retrieving in a manner that is transparent to said user. 41-54. (Canceled) 55. (Previously Presented) A computer implemented method of distributing digital content that is pre-processed by a client device, comprising: a. transmitting, to a client device, pre-processing parameters for digital content at said client device, said digital content including one or more of image content, video content, and audio content, said pre-processing parameters enabling said client device to place said digital content into a specified form in preparation for distribution to one or more devices that are remote from a server device and said client device; b. receiving, from said client device, a plurality of pre-processed digital content items that have been pre-processed using said pre-processing parameters; c. combining at least two of said plurality of pre-processed digital content items into a presentation; and d. distributing said presentation to one or more devices that are remote from said server device and said client device. 56. (Previously Presented) The method of claim 55, wherein said pre-processing parameters include a file format for said digital content items. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 10of35 57. (Previously Presented) The method of claim 55, wherein said pre-processing parameters include a compression ratio for said digital content items. 58. (Previously Presented) The method of claim 55, wherein said pre-processing parameters include a media size or aspect ratio for said digital content items. 59. (Previously Presented) The method of claim 55, wherein said pre-processing parameters include a quality setting for said digital content items. 60. (Canceled) 61. (Previously Presented) The method of claim 55, further comprising transmitting media object identifier code that enables identification of digital content items. 62. (Previously Presented) The method of claim 55, further comprising receiving information associated with said plurality of pre-processed digital content items. 63. (Previously Presented) The method of claim 55, wherein said presentation is animated. 64. (Previously Presented) A computer implemented method for pre-processing digital content at a client device for subsequent electronic publishing, comprising: a. receiving a command that moves a graphical user interface element in a graphical user interface displayed at said client device, said received command enabling 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 11of35 selection of digital content, said digital content including one or more of image content, video content, and audio content; b. pre-processing said selected digital content in accordance with one or more pre-processing parameters that are received from a remote device to produce pre-processed digital content, said one or more pre-processing parameters enabling said client device to place said digital content into a specified form in preparation for publication to one or more devices that are remote from a server device and said client device; c. displaying a preview image of said selected digital content, said preview image having a reduced size relative to said selected digital content; and d. transmitting a message that includes said pre-processed digital content to said server device for subsequent publishing to said one or more devices that are remote from said server device and said client device. 65-79. (Canceled) 80. (Previously Presented) The method of claim 16, wherein said previously received pre- processing parameters enable said client device to place said identified group of one or more items of digital content into a specified form in preparation for publication to one or more devices on which said identified group of one or more items of digital content is to be electronically displayed. 81. (Previously Presented) The method of claim 28, wherein said one or more pre-processing parameters enable said client device to place said digital content into a specified form in 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 12 of35 preparation for publication to one or more devices on which said digital content is to be electronically displayed. 82. (Previously Presented) The method of claim 55, wherein said pre-processing parameters enable said client device to place said digital content into a specified form in preparation for distribution to one or more devices on which said digital content is to be electronically displayed. 83. (Currently Amended) A computer implemented method of publishing digital content that has been pre-processed by a client device, comprising: a. receiving, from said client device, a·pre-processed group of one or more items. of digital content that includes one or more of image content, video content, and audio content, wherein a collective digital content of said group of one or more items of digital content is limited by a specification of an amount of digital content, said group of one or more items of digital content being pre-processed in accordance with pre-processing parameters that were 13reYieusly provided to said client device by a device separate from said client device, said pre-processing parameters eRabliRg controlling said client device te-in a placement of said identified group of one or more items of digital content into a specified form in preparation for distribution to one or more devices that are remote from a server device and said client device; and b. distributing, by said server device via an electronic network, information based on said pre-processed group of one or more items of digital content to one or more devices that are remote from said server device and said client device. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 13 of35 84. (Currently Amended) A computer implemented method of distributing digital content that has been pre-processed by a client device, comprising: a. receiving, from said client device, pre-processed digital content that includes one or more of image content, video content, and audio content, and information retrieved by said client device that enables identification of a user, said retrieved information being available to said client device prior to an identification of said digital content at said client device, wherein said digital content is pre-processed by said client device in accordance with pre-processing parameters that were available provided to said client device ~rior to said ideRtifieatioRby a device separate from said client device, said pre-processing parameters eRaeling controlling said client device te-in a placement of said digital content into a specified form in preparation for distribution to one or more devices that are remote from a server device and said client device; and b. distributing, by said server device via an electronic network, information based on said pre-processed digital content to one or more devices that are remote from said server device and said client device. 85. (Canceled) 86. (New) A computer implemented method for pre-processing digital content in a client device for subsequent electronic distribution, comprising: 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 14 of 35 a. initiating, by said client device, a transfer of digital content from said client device to a server device, said digital content including one or more of image content, video content, and audio content; b. pre-processing said digital content at said client device in accordance with one or more pre-processing parameters, said one or more pre-processing parameters being provided to said client device from a device separate from said client device, said one or more pre-processing parameters controlling said client device in a placement of said digital content into a specified form in preparation for publication to one or more devices that are remote from a server device and said client device; and c. transmitting a message from said client device to said server device for subsequent distribution to said one or more devices that are remote from said server device and said client device, said transmitted message including said pre-processed digital content. 87. (New) The method of claim 86, wherein said pre-processing comprises pre-processing said digital content in accordance with pre-processing parameters that are provided to said client device by said server device. 88. (New) The method of claim 86, further comprising receiving an identification of said digital content for transmission prior to said pre-processing. 89. (New) The method of claim 86, wherein said pre-processing comprises reducing a file size or compressing said digital content. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 15of35 90. (New) The method of claim 86, wherein said pre-processing comprises resizing said digital content. 91. (New) The method of claim 86, wherein said pre-processing comprises changing a file format of said digital content. 92. (New) The method of claim 86, wherein said transmitted message includes identifying information for said digital content. 93. (New) The method of claim 92, wherein said identifying information is retrieved from storage in said client device. 94. (New) The method of claim 93, wherein said identifying information includes a file name. 95. (New) The method of claim 93, wherein said identifying information includes location information. 96. (New) The method of claim 95, wherein said identifying information includes zip code information. 97. (New) The method of claim 93, wherein said identifying information includes user information. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 16of35 98. (New) The method of claim 93, wherein said identifying information includes information describing said digital content. 99. (New) A computer implemented method for distributing digital content that has been pre- processed by a client device, comprising: a. receiving, from said client device, digital content that has been pre-processed at said client device in accordance with one or more pre-processing parameters that have been provided to said client device from a device separate from said client device, said digital content including one or more of image content, video content, and audio content, said one or more pre-processing parameters controlling said client device in a placement of said digital content into a specified form in preparation for distribution to one or more devices that are remote from a server device and said client device; and b. publishing, by said server device via an electronic network, information based on said pre-processed digital content to one or more devices that are remote from said server device and said client device. 100. (New) The method of claim 16, wherein said pre-processing comprises resizing said digital content. 101. (New) The method of claim 28, wherein said pre-processing comprises resizing said digital content. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 17of35 REMARKS Claims remaining in the present patent application are Claims 16-21, 23, 25-29, 31, 33-40, 55-59, 61-64, 80-84 and 86-101. Applicants respectfully assert that no new material is introduced as a result of the amendments herein. Applicants respectfully request consideration of the above captioned patent application in light of the remarks presented herein. L Objections At paragraphs 3 and 4, the Examiner objected to the specification and claims regarding claims 65-78 and 85. Claim 65-78 and 85 have been canceled. The Examiner's objections are thereby rendered moot. II. Rejections Under 35 U.S.C. §112,first paragraph At paragraph 5, the Examiner rejected claims 16-21, 23, 25-29, 31, 33-40, 55-59 and 61-64 and 79-85 as allegedly reciting claim features that were not mentioned or described in the specification. Applicants note that pre-processing is described, for example, at page 8, lines 1-4 and page 9, lines 2-4 of the specification. In general, the client device pre-processes digital content based on pre-processing parameters obtained from another device. This pre- processing is performed prior to upload to a server device. As described, for example, at FIG. 1 and page 4, lines 13-15, pre-processed digital content is transmitted to a server device for storage and subsequent distribution to devices served by the server device. An example 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 18of35 of such a scenario is a web-site listing that includes pre-processed digital content that has been uploaded by a client device. Applicants submit that all recited claim features are fully supported by the specification. The rejection of claims 16-21, 23, 25-29, 31, 33-40, 55-59 and 61-64 and 79- 85 is therefore traversed. IIL Rejections Under 35 U.S.C. §112, second paragraph At paragraph 6, the Examiner rejected claims 16, 23 and 26 as being indefinite for failing to particularly point out and distinctly claim the subject matter that Applicants regard as their invention. By the amendment to those claims, Applicants have accommodated the Examiner's rejection. IV. Rejections Under 35 U.S. C. §103 The Examiner rejected claims 16-21, 23, 25-29, 31, 33-40, 55-59, 61-64 and 80-84 as being unpatentable over U.S. Patent No. 6,237,010 to Hui et al. ("Hui") in view of U.S. Patent No. 6,522,418 to Yokomizo et al. ("Yokomizo"). The Examiner also rejected claims 65-78 and 85 as being unpatentable over Hui in view of Y okomizo and U.S. Patent No. 6,301,486 to Yang et al. Claims 65-78 and 85 have been canceled. The rejection of those claims is therefore rendered moot. Prior to addressing the rejections of claims 16-21, 23, 25-29, 31, 33-40, 55-59, 61-64 and 80-84, a description of the system and method disclosed by Hui is first provided. In general, Hui describes a system and method that creates and publishes a set of images, each 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 19of35 image in the set is stored in a FlashPix file format. The FlashPix file format is described at col. 4, lines 62-67 of Hui as follows: As noted above, FlashPix-format files store raw data for an image as well as additional information relating to the image. Typically, Flashpix files store (1) the image in multiple resolutions, (2) viewing parameters which comprise transformations and the like that affect how the image is displayed, and (3) information relating to the image, such as the date that the image was formed, the hardware device that formed the image, settings on such a hardware device, etc. (Emphasis Added) As this excerpt notes, multiple resolutions of the image are stored in the FlashPix file. Viewing parameters contained within the FlaxhPix file affect how the image is to be displayed. Images that are collected are displayed in a workspace. As noted at col. 10, lines 7- 10, low-resolution images (e.g., thumbnails) from the FlashPix files are displayed in the workspace. Images displayed in the workspace can be corrected. FIG. 11 (reproduced below) illustrates a user interface for correcting images. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 20of35 In this user interface, buttons 100-104 can be used to effect various correction functions. For example, color button 100 can be used to display color controls 109 as indicated in FIG. 12 reproduced below). 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 21of35 Col. 11, lines 25-37 describes the functionality provided by user interface 41 as follows: As shown in FIG. 12, upon selection of "Color" button 100, GUI 41 displays color controls 109, magnification controls 110, and "Reset" radio button 111. Color controls 109 may be used to change viewing parameters in the FlashPix file for image 107. That is, as noted above, changes to an image made via GUI 41 comprise changes to viewing parameters in the image's FlashPix file, and not changes to raw data for the image. In contrast to color controls 109, which can be used to change viewing parameters for an image, magnification controls 110 and "Reset" radio button 111 are editing tools which facilitate image correction, but do not change image viewing parameters. (Emphasis Added) As this excerpt of Hui states, image corrections are made to the viewing parameters, not to the raw data for the image. In a similar manner, corrections using the "Tone," "Filter," "Spatial" and "Info" buttons comprise changes to the viewing parameters and not to raw data for the image. After any image corrections are made, an image composition process can be performed. Like image corrections, image compositions do not impact the raw data for the image. Col. 14, lines 49-57 of Hui describes the scope of the image composition as follows: In a case that image composition is to be performed, processing proceeds to step S309. Step S309 composes images displayed on workbench 60. More specifically, composing step S309 adds information to, or deletes information from, a FlashPix file of a particular image. Such information can include, but is not limited to, written captions, audio information, and information relating to creation and/or capture of the image, such as the type of hardware device used to capture the image and/or settings on the device. (Emphasis Added) As this excerpt of Hui states, the image composition process is directed to adding or deleting information associated with the image, but does not address the image data itself. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 22of35 A. Claims 16-21, 25, 27, 80 and 83 1. Hui does not disclose pre-processing digital content by a client device using pre-processing parameters received from a remote device, the pre- processing parameters controlling a placement of digital content into a specified form for publication With regard to claim 16, the Examiner asserts that Hui pre-processes digital content. As described above, Hui's image correction and composition processes do not modify the image data contained within the FlashPix file. Specifically, the image correction process is designed to modify the viewing parameters (e.g., color, tone, etc.) that control how the image data is to be displayed. The image correction process does not modify the underlying image data contained within the FlashPix file. The composition process of Hui also does not modify the image data contained within the FlashPix file. Rather, the composition process is designed to add or delete information (e.g., written captions) that is separate from the image data. Applicants submit that the image correction and composition processes of Hui are both directed to separate information that is associated with the image data, not to the image data itself. Accordingly, the correction and composition processes of Hui cannot be said to pre-process the digital content, which includes one or more of image content, video content, and audio content. At best, Hui processes information associated with digital content. Even assuming that Hui can be said to disclose some form of processing digital content, Hui does not process digital content using pre-processing parameters received from a remote device, the pre-processing parameters controlling a placement of the digital content into a specified form for publication. More specifically, any image correction or composition processes disclosed by Hui are directed solely by the user. Control is not effected by a 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 23of35 remote device. For example, Hui does not describe a remote device directing an application of specific coloring to an image. Instead, the user controls the specific coloring using the correction process tools made available to the user. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching ofYokomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing of digital content using pre-processing parameters received from a remote device, the pre-processing parameters controlling a placement of the digital content into a specified form for publication. 2. Hui does not disclose receiving an identification of a group of one or more items of digital content, the collective digital content of the group being limited by pre-processing parameters received from a remote device At page 6 of the Office Action, the Examiner asserts that Hui discloses Applicants' "receiving an identification of a group of one or more items of digital content for transmission, a collective digital content being limited by said received specification of said amount of digital content." In claim 16, the collective digital content is limited by pre- 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 24of35 processing parameters that are received from a remote device. Applicants submit that Hui does not disclose such a claimed feature. The Examiner has not identified the specific parameter that effects such a limitation. As the user chooses the set of images apparently without restraint, the Examiner has not identified any portion of Hui that qualifies as a pre- processing parameter received from a remote device that constrains the "collective digital content." 3. Conclusion For any one of the reasons noted above, Applicants submit that claim 16, as well as dependent claims 17-21, 25, 27 and 80, are not disclosed by the combination of Hui and Yokomizo. Claim 83 discloses similar features to claim 16. Accordingly, the rejection of claims 16-21, 25, 27, 80 and 83 is therefore traversed. B. Claim 23 1. Hui does not disclose pre-processing by a client device using pre- processing parameters received from a remote device Claim 23 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the pre-processing of claim 23. As noted above in Section IV.A. I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a remote device. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 25of35 remote image processing stations (Fig. 1)." This alleged teaching ofYokomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing using pre- processing parameters received from a remote device. 2. Hui does not disclose receiving an identification of a group of one or more media objects, the collective media data of the group of one or more media objects being limited by pre-processing parameters received from a remote device In claim 23, the collective media data is limited by pre-processing parameters that are received from a remote device. Applicants submit that Hui does not disclose such a claimed feature. The Examiner has not identified the specific parameter that effects such a limitation. As the user chooses the set of images apparently without restraint, the Examiner has not identified any portion of Hui that qualifies as a pre-processing parameter received from a remote device that constrains the "collective media data." 3. Hui does not disclose pre-processing by a client device that changes a file format At page 10 of the Office Action, the Examiner refers to col. 1, lines 40-48. The Examiner does not specify whether the reference is to Hui or Y okomizo. Col. 1, lines 40-48 of Hui makes reference to a FlashPix file format, while col. 1, lines 40-48 of Y okomizo makes reference to a JPEG format. As neither reference discloses converting between the 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 26of35 JPEG and FlashPix file formats, the combination of Hui and Y okomizo cannot show claim 23's pre-processing, wherein the pre-processing comprises changing a file format of the media object. 4. Conclusion For any one of the reasons noted above, Applicants submit that claim 23 is not disclosed by the combination of Hui and Yokomizo. The rejection of claim 23 is therefore traversed. C. Claim 26 1. Hui does not disclose pre-processing by a client device using pre- processing parameters received from a remote device Claim 26 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the pre-processing of claim 26. As noted above in Section IV.A. I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a remote device. Accordingly, Hui fails to show pre-processing using pre-processing parameters received from a remote device. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching ofYokomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 27of35 remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing using pre- processing parameters received from a remote device. 2. Hui does not disclose receiving an identification of a group of one or more media objects, the collective media data of the group of one or more media objects being limited by pre-processing parameters received from a remote device In claim 26, the collective media data is limited by pre-processing parameters that are received from a remote device. Applicants submit that Hui does not disclose such a claimed feature. The Examiner has not identified the specific parameter that effects such a limitation. As the user chooses the set of images apparently without restraint, the Examiner has not identified any portion of Hui that qualifies as a pre-processing parameter received from a remote device that constrains the "collective media data." 3. Conclusion For any one ofreasons noted above, Applicants submit that claim 26 is not disclosed by the combination of Hui and Yokomizo. The rejection of claim 26 is therefore traversed. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 28of35 D. Claims 28, 29, 33, 35-40, 81 and 84 1. Hui does not disclose pre-processing by a client device using pre- processing parameters received from a device separate from the client device Claim 28 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the pre-processing of claim 28. As noted above in Section IV.A. I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-parameters received from a device separate from the client device. Accordingly, Hui fails to show pre-processing using pre-processing parameters received from a device separate from the client device, the pre-processing parameters controlling the client device in a placement of the digital content into a specified form in preparation for publication. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching ofYokomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing of digital content using pre-processing parameters received from a device separate from the client device, the pre-processing parameters controlling a placement of the digital content into a specified form for publication. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 29of35 2. Hui does not disclose retrieving information that enables identification of a user Claim 28 was rejected substantially on the same grounds as claim 16. As distinct from claim 16, claim 28 recites retrieving information that enables identification of a user, the retrieved information being available to the client device prior to the received identification. The Examiner's rejection of claim 28 did not refer to this feature, nor did it identify any portion of Hui or Yokomizo that related to that feature. 3. Conclusion For any one of the reasons noted above, Applicants submit that claim 28, as well as dependent claims 29, 33, 35-40 and 81, is not disclosed by the combination of Hui and Yokomizo. Claim 84 discloses similar features to claim 28. Accordingly, the rejection of claims 28, 29, 33, 35-40, 81 and 84 is therefore traversed. E. Claim 31 1. Hui does not disclose pre-processing by a client device using pre- processing parameters received from a device separate from the client device Claim 31 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the pre-processing of claim 16. As noted above in Section IV.A. I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a device separate from the client device. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 30of35 processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching of Y okomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing using pre- processing parameters received from a device separate from the client device. 2. Hui does not disclose retrieving information that enables identification of a user Claim 31 recites retrieving information that enables identification of a user, the retrieved information being available to the client device prior to the received identification. The Examiner's rejection of claim 31 did not refer to this feature, nor did it identify any portion of Hui or Y okomizo that related to that feature. 3. Hui does not disclose pre-processing by a client device that changes a file format At page 10 of the Office Action, the Examiner refers to col. 1, lines 40-48. The Examiner does not specify whether the reference is to Hui or Y okomizo. Col. 1, lines 40-48 of Hui makes reference to a FlashPix file format, while col. 1, lines 40-48 of Y okomizo makes reference to a JPEG format. As neither reference discloses converting between the 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 31of35 JPEG and FlashPix file formats, the combination of Hui and Y okomizo cannot show claim 31 's pre-processing wherein the pre-processing comprises changing a file format. 4. Conclusion For any of the reasons noted above, Applicants submit that claim 31 is not disclosed by the combination of Hui and Yokomizo. The rejection of claim 31 is therefore traversed. F. Claim 34 1. Hui does not disclose pre-processing by a client device using pre- processing parameters received from a device separate from the client device Claim 34 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the pre-processing of claim 34. As noted above in Section IV.A. I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a device separate from the client device. Accordingly, Hui fails to show pre-processing using pre-processing parameters received from a device separate from the client device. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching ofYokomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 32of35 Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing using pre- processing parameters received from a device separate from the client device. 2. Hui does not disclose retrieving information that enables identification of a user Claim 34 recites retrieving information that enables identification of a user, the retrieved information being available to the client device prior to the received identification. The Examiner's rejection of claim 34 did not refer to this feature, nor did it identify any portion of Hui or Y okomizo that related to that feature. 3. Conclusion For any of the reasons noted above, Applicants submit that claim 34 is not disclosed by the combination of Hui and Yokomizo. The rejection of claim 34 is therefore traversed. G. Claims 55-59, 61-63 and 82 1. Hui does not disclose transmitting pre-processing parameters to a client device, the pre-processing parameters enabling the client device to place digital content into a specified form in preparation for distribution Claim 55 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the transmitting of pre-processing parameters to a client device. As noted above in Section IV.A.I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a device separate from the client device. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 33of35 The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching ofYokomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose transmitting pre-processing parameters to a client device, the pre-processing parameters enabling the client device to place digital content into a specified form in preparation for distribution. 2. Hui does not disclose combining at least two of the plurality ofpre- processed digital content items into a presentation As noted above, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a remote device. Accordingly, Hui does not disclose receiving pre-processed digital content items from a client device. As Hui does not disclose receiving pre-processed digital content items from a client device, Hui cannot disclose combining at least two of a plurality of pre-processed digital content items received from the client device into a presentation. The Examiner's reference at page 13 of the Office Action to the addition of audio to a displayed image is not dispositive. Here, Applicants note that Hui adds audio at the client 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 34of35 device, not at a device that receives the audio and the image data from the client device. In general, the Examiner refers to actions of a client device in Hui, while claim 55 refers to actions in a device that corresponds with a client device. 3. Conclusion For any of the reasons noted above, Applicants submit that claim 55, as well as dependent claims 56-59, 61-63 and 82, are neither disclosed nor suggested by Hui in view of Yokomizo. The rejection of claims 55-59, 61-63 and 82 is therefore traversed. H. Claim 64 1. Hui does not disclose pre-processing by a client device using pre- processing parameters received from a remote device Claim 64 was rejected substantially on the same grounds as claim 16, wherein the Examiner relied on Hui to show the pre-processing of claim 64. As noted above in Section IV.A. I, Hui (1) does not process actual image data, and (2) such processing is not performed using pre-processing parameters received from a remote device. The deficiencies of Hui are not made up by Y okomizo. Y okomizo was relied upon by the Examiner solely for the alleged disclosure of "an image processing method for processing an image in a system having a plurality of remote image processing stations and a server image processing station which is capable of communicating with the plurality of remote image processing stations (Fig. 1)." This alleged teaching of Y okomizo was introduced to address the admitted deficiency of Hui as not showing "the server and other remote devices that the network interface 29 communicate/connect to." See, page 7 of the Office Action. 6 Appl. No.: 10/961,720 Inventor: Wood et al. Page 35of35 Thus, even assuming that Y okomizo teaches all that the Examiner alleges, Y okomizo does not cure the deficiencies of Hui in its failure to disclose pre-processing using pre- processing parameters received from a remote device, the pre-processing parameters enabling the client device to place the digital content into a specified form in preparation for publication. 2. Conclusion For at least the reasons noted above, Applicants submit that claim 64 is not disclosed by the combination of Hui and Y okomizo. The rejection of claim 64 is therefore traversed. Conclusion All of the stated grounds of rejection have been properly traversed, accommodated, or rendered moot. Applicants therefore respectfully request that the Examiner reconsider all presently outstanding rejections, and that they be withdrawn. The Examiner is invited to telephone the undersigned representative if an interview might be useful for any reason. Respectfully submitted, Dated: March 26, 2010 By: /duane s. kobayashi/ Duane S. Kobayashi Law Office of Duane S. Kobayashi Reg. No. 41122 1325 Murray Downs Way Reston, VA 20194 Tel: 703-437-8000 Fax: 703-935-0276