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`Docket No.: 083710-2481
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`Introduction
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`REMARKS
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`Claims 1, 4-5, 7-11, 19-21, and 24-30 are pending, of which claims 1 and 24 are
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`independent.
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`Claims 1, 5, 9, and 24 have been amendedto correct informalities in the claim language
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`and to more clearly define the present subject matter. Claims 12-18 and 22-23 have been
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`cancelled without prejudice. New claim 30 has been added. The amendments of claims 1 and 24
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`are supported by, for example, original claims 6 and 9, and paragraphs [0027], [0038] of the
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`published present application (US2019/0145571). New claim 30 is supported by, for example,
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`original claims 9. No new matter has been added.
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`Substance of Interview
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`Applicant thanks the Examinerfor his time and courtesy during an interview conducted
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`with the Applicant’s representative, Takashi Saito, on February 7, 2023. During the interview,
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`the differences between the claims and the prior art were discussed. No agreement was reached.
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`This responsereflects the substance of the interview.
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`Claim Rejections Under 35 U.S.C. § 112
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`Claims 12-18, 22, and 23 are rejected under AJA 35 U.S.C. 112(a) as failing to comply
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`with the enablement requirement. Claims 12-18, 22, and 23 are rejected under AIA 35 U.S.C.
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`112(b) as being indefinite.
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`Without conceding the correctness of the rejection, claims 12-18, 22 and 23 have been
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`cancelled.
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`
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`Application No. 16/228,742
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`Docket No.: 083710-2481
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`Claim Rejections Under 35 U.S.C. § 103
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`Claims 1, 5, 7 and 9-23 were rejected under 35 U.S.C. 103 as being unpatentable over
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`Shibata (WO 2014/132652) in view of Goulet (US 2009/0258180) and Kobayashi (US
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`6368712). Claims 1, 4, 5, 7 and 9-23 were rejected under 35 U.S.C. 103 as being unpatentable
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`over Shibata in view of Goulet, Kobayashi and Besselievre (US2014/0252263). Claims 8 and
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`24-29 wererejected under 35 U.S.C. 103 as being unpatentable over Shibata in view of Goulet,
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`Kobayashi, Besselievre and Oh (US2016/0264427). Without conceding any correctness of the
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`rejections, Applicant traverses the rejections for at least the following reasons.
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`Regarding claims 1 and 24, at a minimum, noneofthe cited references teaches the
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`feature “the silica xerogelis filled in the nonwoven fabric to form a single layer essentially
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`consisting of the nonwovenfabric andthesilica xerogel.” In the present application, as shown in
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`pages 10-12, the insulating material as a single layer is formed poring a sol solution onto a
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`nonwoven fabric. Thus, the single layer essentially consists of the nonwoven fabric and the
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`silica xerogel.
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`The Office Action asserted that Shibata teaches a heat insulating structure including an
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`aerogel layer including aerogel particles and the aerogel may include xerogel.
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`However, Shibata at most discloses a layer containing a holding material 3 (resin) and
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`fibrous substance 3 disposed overan airgel layer 1. Thus, Shibata fails to disclose the
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`aforementioned features of claims 1 and 24. The remaining cited references do not cure the
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`deficiencies of Shibata.
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`Further, none of the cited references disclose or suggestthat the plurality of nonwoven
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`fabric fibers comprise the carboxyl group, as recited by claims 1 and 24. Regarding modification
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`by a carboxyl group, the Office Action relied on Kobayashi.
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`
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`Application No. 16/228,742
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`Docket No.: 083710-2481
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`However, Applicant submits that it is considered that the carboxyl group in Kobayashi
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`would not be present on the surface of the fibers by the following reasons. If an epoxyresin is
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`used as the matrix resin in Kobayashi, the groups capable of reacting with the epoxyresin, i.e.,
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`carboxyl group, would react with the epoxy resin and be bondedto the epoxy resin. When the
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`carboxyl group reacts with the epoxyresin, the following chemical reaction would happen:
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`
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`In this regard, the carboxyl group in Kobayashi would not be present on the surface of the fibers.
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`Thatis, the teaching of Kobayashi as a whole indicates that no carboxyl group on the surface of
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`fibers. Therefore, the combinedreferencesfail to teach the feature “the plurality of nonwoven
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`fabric fibers comprise the carboxyl group” of claims 1 and 24.
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`Assuch, claims 1 and 24 andall claims dependentthereon are patentable overthe cited
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`references.
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`
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`Application No. 16/228,742
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`Docket No.: 083710-2481
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`CONCLUSION
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`Having fully respondedto all matters raised in the Office Action, Applicant submits that
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`all claims are in condition for allowance, an indication for whichis respectfully solicited. If
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`there are any outstanding issues that might be resolved by an interview or an Examiner’s
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`amendment, the Examineris requested to call Applicant’s attorney at the telephone number
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`shownbelow.
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`To the extent necessary, a petition for an extension of time under 37 C.F.R. § 1.136 is
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`hereby made. Please charge any shortage in fees due in connection with the filing of this paper,
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`including extension of time fees, to Deposit Account 500417 and please credit any excess fees to
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`such deposit account.
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`Respectfully submitted,
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`McDERMOTT WILL & EMERY LLP
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`/Takashi Saito/
`
`Takashi Saito
`Registration No. 69,536
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`Please recognize our Customer No. 53080
`as our correspondenceaddress.
`
`500 North Capitol Street, N.W.
`Washington, DC 20001-1531
`Phone: 202.756.8244
`Facsimile: 202.756.8087
`Date: February 15, 2023
`
`