Application No.: 17/296,825
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`Docket No.: 070469-1079
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`I
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`Introduction
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`REMARKS
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`In response to the pending Office Action, Applicants have amended claims 1, 3, 12, 14 and
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`15 so as to address the rejection of the claims under 35 U.S.C. § 112, second paragraph, and to
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`clearly distinguish the pending claims overthe cited prior art references. Each of claims 1, 3, 14
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`and 15 have been amendedto include the subject matter of original claim 4, which has been
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`cancelled. No new matter has been added.
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`Forat least the following reasons, it is respectfully submitted that all pending claims are in
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`condition for allowance.
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`IL.
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`The Rejection Of The Claims Under 35 U.S.C. § 112, Second Paragraph
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`Claims 3, 12, 13 and 15 were rejected under 35 U.S.C. § 112, second paragraph, as being
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`indefinite for not reciting various elements in proper numerical/ordinal order. In response,
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`Applicants have amended claims 3, 12 and 15 such that the elements in question are referred to as
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`first, second etc. It is respectfully submitted that the foregoing amendmentsto the claims addresses
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`the basis of the rejection and that the rejection has been overcome.
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`Il.
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`The Rejection Of The Claims Under 35 U.S.C. § 103
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`Claims 1-9 and 12-15 were rejected under 35 U.S.C. § 103 as being obvious over USP Pub.
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`No. 2018/0137876 to Sun in view of USP Pub. No. 2012/0109632 to Suguira and in view of USP
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`Pub. No. 2014/0053423 to Nishikawa. Forat least the following reasons, it is respectfully
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`submitted that the amendedclaims are patentable over Sun, Suguira and Nishikawa, taken alone or
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`in combination with one another.
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`Application No.: 17/296,825
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`Docket No.: 070469-1079
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`Claim 1, as amended,recites in-part:
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`afirst crosstalk canceller that, whenfirst crosstalk refers to a phenomenonin which
`the first voice enters into the second microphone, estimates afirst crosstalk signal indicating
`the first crosstalkfrom the first voice and removesthe first crosstalk signalfrom the output
`signal of the second microphone; and
`a second crosstalk canceller that, when second crosstalk refers to a phenomenon in
`which the second voice enters into the first microphone, estimates a second crosstalk signal
`indicating the second crosstalkfrom the second voice and removes the second crosstalk
`signalfrom the output signalof the first microphone.
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`Thus, as amended, claim 1 recites first and second crosstalk cancellers, where first crosstalk
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`is defined as the first voice of a first speaker entering into the second microphone, and the second
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`crosstalk is defined as the second voice of a second speaker entering into the first microphone. In
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`other words, the first crosstalk is a phenomenon in whichthe first voice of the first speaker which is
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`supposed to enter into the first microphoneenters into the second microphone, and the second
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`crosstalk is a phenomenonin which the second voice of the second speaker which is supposed to
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`enter into the second microphoneenters into the first microphone.
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`Further, as also recited by amendedclaim 1, the first crosstalk canceller estimates the first
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`crosstalk signal indicating the first crosstalk from the first voice that has entered the second
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`microphone and removesthe first crosstalk signal from the output signal of the second microphone,
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`and the second crosstalk canceller estimates a second crosstalk signal indicating the second
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`crosstalk from the second voice that enters the first microphone and removes the second crosstalk
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`signal from the output signal of the first microphone.
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`As detailed in the specification, see, e.g, paragraph [0203] of the specification, the
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`translation device of claim | allows conversations between two speakers while stably recognizing
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`voices by removing acoustic noise including echa, even in the case where voices of a plurality of
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`speakers and a plurality of synthesized voices are present simullancously overlapping one another,
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`Application No.: 17/296,825
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`Docket No.: 070469-1079
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`At a minimum,noneofthe cited prior art references disclose or suggest the recited first
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`crosstalk canceller or the second crosstalk canceller recited by claim 1. Indeed, noneofthe cited
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`references even appearto discuss first or second crosstalk as defined by amended claim 1, muchless
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`a device for cancelling such crosstalk. In the pending rejection of claim 4 it is asserted that Sun
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`discloses the recited first and second crosstalk cancellers. However, Sun merely discloses methods
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`for cancelling sounds output from a speaker unit of a second device from affecting the output of the
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`speakerunit of a first device. Sun is completely silent with respect to the issue that the voice(first
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`voice) of a single person (e.g., first speaker) enters into plural microphones(first and second
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`microphones), much less how to address such anissue.
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`Thus, Sun does not disclose or suggest a device having afirst crosstalk canceller that, when
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`first crosstalk refers to a phenomenon in which the first voice enters into the second microphone,
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`estimates afirst crosstalk signal indicating the first crosstalkfrom the first voice and removesthe
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`first crosstalk signalfrom the output signal of the second microphone; and a second crosstalk
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`canceller that, when second crosstalk refers to a phenomenon in which the second voice enters into
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`the first microphone, estimates a second crosstalk signal indicating the second crosstalkfrom the
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`second voice and removesthe second crosstalk signalfrom the output signal of the first
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`microphone, as recited by amended claim 1.
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`Neither Suguira nor Nishikawa cure the foregoing deficiencies of Sun, nor are they relied
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`upon as doing so.
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`Thus, for at least the foregoing reasons, it is respectfully submitted that claim 1, as amended,
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`is patentable over the cited prior art references, taken alone or in combination with one another.
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`Asclaims 3, 14 and 15 have been amended in substantially the same manneras claim 1, it is
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`respectfully submitted that claims 3, 14 and 15 are also patentable over the cited prior art references.
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`Application No.: 17/296,825
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`Docket No.: 070469-1079
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`Turning to claim 12, claim 12 recites in-part:
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`a summing circuit that sums the first translated voice output from thefirst voice
`synthesis circuit and the second translated voice output from the second voice synthesis
`circuit to output a sum translated voice.
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`In the pending rejection it is asserted that Sun discloses the recited “summing circuit” of
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`claim 12. Sun discloses “adding a presentation soundto the speaker output signal”(see, e.g.,
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`paragraph [0108]). Importantly, however, Sun merely discloses an example in which this
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`“presentation sound” is “TUM”that is often used in the car navigation system (see, e.g., paragraph
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`[0080]). Nowhere does Sun disclose or suggest a summing circuit that_ sums the first translated
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`voice output from the first voice synthesis circuit and the second translated voice output from the
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`second voice synthesis circuit to output a sum translated voice, as recited by claim 12.
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`Sugiura and Nishikawaalso fail to disclose the recited summing circuit of claim 12, nor are
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`they relied upon as doingso.
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`Accordingly, claim 12 is also patentable over the cited prior art references taken alone or in
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`combination with one another.
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`IV.
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`Dependent Claims
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`UnderFederal Circuit guidelines, a dependent claim is nonobviousif the independent claim
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`upon which it dependsis allowable becauseall the limitations of the independent claim are
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`contained in the dependent claims, Hartness InternationalInc. v. Simplimatic Engineering Co., 819
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`F.2d at 1100, 1108 (Fed. Cir. 1987). Accordingly, as the pending independent claims are patentable
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`for at least the reasonsset forth above,it 1s respectfully submitted that all claims dependent thereon
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`are also patentable.
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`Application No.: 17/296,825
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`Docket No.: 070469-1079
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`V.
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`Summary
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`Applicants submit thatall of the claims are now in condition for allowance, an indication of
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`whichis respectfully solicited.
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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 505992 and please credit any excess fees to
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`such deposit account.
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`Respectfully submitted,
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`Rimon,P.C.
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`/Michael E. Fogarty/
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`Michael E. Fogarty
`Registration No. 36,139
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`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Phone: (571) 765-7716
`Facsimile: (571) 765-7716
`Date: January 4, 2024
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`Please recognize our Customer No. 53080 as
`our correspondence address.
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