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Application N0.: 15/892,146
`
`Introduction
`
`REMARKS
`
`Claims 1-3 and 5-20 are pending, of which claim 1 is independent.
`
`Claims 1, 5, 6, 10 and 11 have been amended to correct informalities in the claim
`
`language and to more clearly define the present subject matter. Claim 4 has been cancelled.
`
`Claims 12-20 have been added. The amendments and the new claims are supported by, for
`
`example, FIGS. 7, 9 and 12 and the corresponding description thereof in the specification. No
`
`new matter has been added.
`
`Interpretation of the claim language under 35 U.S.C. § 112(f)
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`The Examiner asserted that the term “control unit” of claim 1 is interpreted as “unit for
`
`control” and thus invokes 35 U.S.C. § 112(1). Applicant disagrees. The claim does not recite
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`“unit for control” and the Examiner cannot change the claim language to apply 35 U.S.C. §
`
`112(i), The control unit in the claims is not modified functional language but rather modified
`
`with structural limitation. Thus, the term “control unit” of the present claims does n_ot invoke 35
`
`U.S.C. § 112(0. Similarly, “a first refrigeration unit” and “a second refrigeration unit” are not
`
`modified functional language, these terms do does n_ot invoke 35 U.S.C. § 112(t).
`
`Patentability under 35 U.S.C. § 112
`
`Claims 1-3 and 5—20 were rejected under 35 U.S.C. § 112(b) as being indefinite.
`
`Applicant submits that the amendments made to the claims overcome the rejection.
`
`DMgUS 165658884-10921220057
`
`

`

`Application No.: 15/892,146
`
`CONCLUSION
`
`Having fully responded to all matters raised in the Office Action, Applicant submits that
`
`all claims are in condition for allowance, an indication for which is respectfully solicited. If
`
`there are any outstanding issues that might be resolved by an interview or an Examiner’s
`
`amendment, the Examiner is requested to call Applicant’s attorney at the telephone number
`
`shown below.
`
`To the extent necessary, a petition for an extension of time under 37 C.F.R. § 1.136 is
`
`hereby made. Please charge any shortage in fees due in connection with the filing of this paper,
`
`including extension of time fees, to Deposit Account 500417 and please credit any excess fees to
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`such deposit account.
`
`Respectfully submitted,
`
`MCDERMOTT KILL & EMERY LLP
`
`W T
`
`akashi Saito
`
`Registration No. 69,536
`
`Please recognize our Customer No. 20277
`as our correspondence address.
`
`500 North Capitol Street, NW.
`Washington, DC 20001-1531
`Phone: 202.756.8000 MEF:TS:
`
`Facsimile: 202.756.8087
`
`Date: March 5, 2020
`
`DMwUS 16565888440921220057
`
`

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