REMARKS
`
`In an Office Action dated August 20, 2020, claims 1-9, 12-16, 19-27, and 30-34 were
`
`rejected. Herein, claims 1 and 16 have been amended and newclaims 37-41 have been added.
`
`No new matter has been added. Additionally, claims 19-36 have been cancelled without
`
`prejudice or disclaimer to the subject matter therein. Applicant respectfully requests further
`
`examination and reconsideration in view of the following remarks.
`
`Applicant would like to thank the Examinerfor indicating that claims 10, 11, 28, and 29
`
`contain allowable subject matter.
`
`I
`
`Support for Amendment
`
`Support for new claims 37-40 is foundat least at lines 13-19 on page 54 and lines 13-25
`
`on page 69 ofthe specification as originally filed. Accordingly, no new matter has been added.
`
`I.
`
`Objection to the Claims
`
`Claims 2, 5, 12, and 13 were objected to for minor informalities. In particular, the
`
`Examinerstates the following:
`
`“Claims 2, 5, 12 and 13 are objected to because of the following informalities:
`“the second quantization” of claim 1
`is referred to, however, claim 1 only
`discusses “a secondary quantization”. The wording in claims 2, 5, 12 and 13
`should be changed to “the secondary quantization”. Appropriate correction is
`required.
`
`Applicant notes that claim 1 has been amended to change “secondary quantization” to
`
`--second quantization--. Accordingly,it is respectfully requested that the objection to claims 2,
`
`5, 12, and 13 be withdrawn.
`
`Il.
`
`Claim Rejection under 35 U.S.C. 103
`
`Claims 1-9, 12-16, 19-27, and 30-34 were rejected under 35 U.S.C. 103 as being
`
`unpatentable over Shibahara (US 2012/0128065) in view of Chen (Algorithm Description of
`
`Joint Exploration Test Model 5 (JEM 5)”, JVET-E1001-v2, January 2017). As noted above,
`
`claims 19-27 and 30-34 have been cancelled without prejudice or disclaimer to the subject matter
`
`

`

`therein. Applicant respectfully requests reconsideration of the above-noted rejection of pending
`
`claims 1-9 and 12-16 in view ofthe following.
`
`Claim 1 recites the following features:
`
`determines whether a secondary transform is to be applied to the current block;
`
`(i) calculates quantized primary coefficients by performing a first quantization on the
`
`primary coefficients when the secondary transform is not to be applied, (11) performs a secondary
`
`transform from the primary coefficients to secondary coefficients, and calculates quantized
`
`secondary coefficients by performing a second quantization on the secondary coefficients when
`
`the secondary transform is to be applied, the second quantization being different from the first
`
`quantization.
`
`Applicant respectfully submits that the above-noted features of claim 1 are not disclosed,
`
`suggested, or otherwise rendered obvious by any combination of Shibahara and Chen based on
`
`the following.
`
`Onpage 4 of the Office Action, the Examinerstates the following:
`
`secondary
`“Shibahara does not explicitly disclose determining whether a
`transform is to be applied to the current block and generating an encoded
`bitstream by encoding either the quantized primary coefficients or the quantized
`secondary coefficients. ...
`
`It would have been obvious to one of ordinary skill in the art before the effective
`filing date of the claimed invention to modify Shibahara’s encoder with the
`missing limitations as taught by Chen to reduce complexity and lower processing
`cost as a result of not always applying the secondary transform (Chen p. 29,
`section 2.4.3, first paragraph).”
`
`However, Applicant notes that paragraphs [0016], [0017], and [0019] of Shibahara
`
`discloses the following:
`
`the amount of
`“T0016] As above, because the KLT has the problem that
`computation is large and the amount of data of transform coefficients is large, it
`used to be hard to utilize the KLT in the conventional coding.
`
`[0017] Thus, the present invention has bee devised to solve the above problem
`and has an object to provide a coding method and a coding apparatus by which an
`increase in the amount of computation and an increase in the amount of data of
`transform coefficients are suppressed so that higher, coding efficiency can be
`
`9
`
`

`

`attained. Furthermore, the present invention has an object to provide a decoding
`method and decoding apparatus by which a signal coded by the coding method
`and the coding apparatus according to an implementation of the present invention
`can be correctly decoded.
`
`[0019] With this, the transform processing has two stages: the first transform and
`the second transform, which suppresses the increase of the amount of computation
`and the increase of the amount of data of transform coefficients, so that higher
`coding efficiency can be attained. For example,
`the transform processing
`performed at two stages with different accuracy levels requires a smaller amount
`of computation than in the transform processing performed at one stage with high
`accuracy and achieves a transform with higher accuracy than in the transform
`processing performed at one stage with a small amount of computation.
`Furthermore, in performing the two-stage transform, the second transform can be
`more appropriate by performing modification using a scaling parameter which is
`used in quantization.” (emphasis added).
`
`Based on the above disclosure of Shibahara, Applicant respectfully submits that the
`
`two-stage transform is to be always performed for coding blocks according to the operation of
`
`the invention taught by Shibahara. By adopting the two-stage transform, Shibahara teaches that
`
`itis only necessary for a portion of the signal for a coding block to undergo the second
`
`transform, and as such, Shibahara explains that this enables a higher accuracy while minimizing
`
`the computational load.
`
`Accordingly, Applicant notes that the principle of operation of the Shibahara reference
`
`is that the two-stage transform is always performedin order to enable the benefit of higher
`
`accuracy while minimizing the computational load, and as such, it is respectfully submitted that
`
`one of ordinary skill in the art would not have modified the teachings of Shibahara based on
`
`those of Chen to skip the second transform described by Shibahara because such a modification
`
`would change the principle of operation of the Shibahara reference (See MPEP 2143.01(VD:
`
`“Ti]f the proposed modification or combination of the prior art would change the principle of
`
`operation of the prior art invention being modified, then the teachings of the references are not
`
`sufficient to render the claims primafacie obvious.”).
`
`10
`
`

`

`In view of the above, Applicant respectfully submits that any combination of Shibahara
`
`and Chenfails to disclose, suggest, or otherwise render obvious the above-noted features of
`
`claim 1. Accordingly, claim 1 is patentable over any combination of Shibahara and Chen.
`
`Claims 2-9 and 12-15 are patentable over any combination of Shibahara and Chen based
`
`at least on their dependency from claim 1.
`
`Claim 16 recites features generally corresponding to the above-noted features of claim 1.
`
`Accordingly, Applicant respectfully submits that any combination of Shibahara and Chenfails to
`
`disclose, suggest, or otherwise render obvious these corresponding features of claim 16 for
`
`reasons similar to those discussed above with respect to claim 1, and as such, claim 16 is
`
`patentable over any combination of Shibahara and Chen.
`
`IV.
`
`Allowable Subject Matter
`
`Claims 10, 11, 28 and 29 were objected to being dependenton a rejected base claim. As
`
`noted above, claims 28 and 29 have been cancelled without prejudice or disclaimer to the subject
`
`matter therein. Applicant respectfully requests that the objection to pending claims 10 and 11 be
`
`withdrawn based on the allowability of independent claim 1, as discussed above.
`
`Vv.
`
`New Claims 37-41
`
`Newclaims 37-40 are patentable over any combination of Shibahara and Chen based at
`
`least on their respective dependency from claims 1 and 16.
`
`Newclaim 41 recites the following features:
`
`perform a primary transform and a secondary transform to convert residuals in a current
`
`block to coefficients; and
`
`quantize the coefficients with no quantization matrix to generate quantized coefficients.
`
`Applicant respectfully submits that the above-noted features of claim 41 are not
`
`disclosed, suggested, or otherwise rendered obvious by any combination of Shibahara and Chen
`
`based on the following.
`
`11
`
`

`

`In the rejection of claim 12 on page 7 of the Office Action, the Examinerstates the
`
`following:
`
`“wherein the first quantization is a weighted quantization in which a quantization
`matrix is used (Shibahara [0109] and [0113]), and
`
`the second quantization is a non-weighted quantization (Shibahara [0020]) in
`which no quantization matrix is used (Shibahara [0020] and [0109]).”
`
`However, Applicant submits that Shibaharafails to disclose circuitry configured to
`
`“perform a primary transform and a secondary transform to convert residuals in a current block
`
`to coefficients” and “quantize the coefficients with no quantization matrix to generate
`
`quantized coefficients,” as required by the above-noted features of new claim 41.
`
`In this regard, although paragraph [0113] of Shibahara discloses “[t]he modification-
`
`absent quantization unit 141 generates the first quantized coefficients Ci1™ by quantizing the
`
`second transformed output signal y2™ without using the norm modification value that is the
`
`above scaling parameter (cf. Expressions 6 and 7),” paragraph [0113] of Shibahara does not
`
`disclose that no quantization matrix is used to quantize the second transformed output signal y2™.
`
`On the contrary, Shibahara describes that a quantization matrix, which has
`
`weightScale(i,j) as an element, is used to quantize the second transformed output signal y2™,
`
`because paragraph [0110] of Shibahara describes the following:
`
`“For example, as indicated by Expression 5, the level scale LevelScale(k,i, j) is
`determined by multiplying
`the value weightScale(i,j) of an element in the
`quantization matrix by the norm modification value normAdjust(k,1j).
`In
`Embodiment
`1,
`as will
`be
`described
`below,
`the
`second
`transform
`unit 130 modifies the first partial signal yir™or the second transform matrix
`Ao™ using the norm modification value as the predetermined scaling parameter.”
`(emphasis added).
`
`Accordingly, Shibahara necessarily fails to disclose circuitry configured to “perform a
`
`primary transform and a secondary transform to convert residuals in a current block to
`
`coefficients” and “quantize the coefficients with no quantization matrix to generate quantized
`
`coefficients,” as required by the above-noted features of new claim 41.
`
`12
`
`

`

`In view of the above, Applicant respectfully submits that any combination of Shibahara
`
`and Chenfails to disclose, suggest, or otherwise render obvious the above-noted features of
`
`claim 41. Accordingly, claim 41 is patentable over any combination of Shibahara and Chen.
`
`VI.
`
`Conclusion
`
`In view of the foregoing amendments and remarks, Applicant respectfully submits that
`
`claims 1-18 and 37-41 are clearly in condition for allowance. An early notice thereofis earnestly
`
`solicited.
`
`If, after reviewing this Amendment, the Examinerbelieves that there are any issues
`
`remaining which mustbe resolved before the application can be passedtoissue, it is respectfully
`
`requested that the Examiner contact the undersigned by telephonein order to resolve such issues.
`
`Respectfully submitted,
`/Stephen W. Kopchik/
`2020.12.15 08:08:35 -05'00'
`
`
`Stephen W. Kopchik
`Registration No. 61,215
`Attorney for Applicant
`
`WENDEROTH, LIND & PONACK,L.L.P.
`1025 Connecticut Avenue, N.W., Suite 500
`Washington, D.C. 20036
`Telephone (202) 721-8200
`Facsimile (202) 721-8250
`December 15, 2020
`
`The Director is hereby authorized to charge anyfees which may be required, or credit any overpayment
`to Deposit Account No. 23-0975.
`
`13
`
`