REMARKS
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`In an Office Action dated January 13, 2021, claims 1-9, 12-16, and 37-41 were rejected.
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`Herein, claims 1, 13, 15, and 16 have been amended. No new matter has been added.
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`Additionally, claims 17, 18, and 37-41 have been cancelled without prejudice or disclaimer to
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`the subject matter therein. Applicant respectfully requests further examination and
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`reconsideration in view of the following remarks.
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`Applicant would like to thank the Examinerfor indicating that claims 10 and 11 contain
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`allowable subject matter.
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`L
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`Support for Amendment
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`Support for the amendmentsto the claims is found at least at paragraphs [0291] and
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`[0349] of US 2020/0162738, whichis the pre-grant publication of the instant application.
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`Accordingly, no new matter has been added.
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`I.
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`Claim Rejections under 35 U.S.C. 102/103
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`Claims 1-9, 12-16, 37, and 39 were rejected under 35 U.S.C. 103 as being unpatentable
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`over Shibahara (US 2012/0128065) in view of Chen (Algorithm Description of Joint Exploration
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`Test Model 5 (JEM 5)’, JVET-E1001-v2, January 2017). As noted above, claims 37 and 39
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`have been cancelled without prejudice or disclaimer to the subject matter therein. Applicant
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`respectfully submits that pending claims 1-9 and 12-16 are patentable over any combination of
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`Shibahara and Chen in view ofthe following.
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`Claim 1 recites the following features:
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`(i) when the secondary transform is not to be applied, calculates quantized primary
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`coefficients by performing a first quantization on the primary coefficients using a quantization
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`matrix, the quantization matrix including quantization steps by which the respective primary
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`coefficients are divided, and (ii) when the secondary transform is to be applied, performs a
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`secondary transform from the primary coefficients to secondary coefficients, and calculates
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`quantized secondary coefficients by performing a second quantization on the secondary
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`coefficients, the second quantization using a quantization step by which each of the secondary
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`coefficients is divided, the quantization step being common between the secondary coefficients.
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`Applicant respectfully submits that the above-noted features of claim 1 are not disclosed,
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`suggested, or otherwise rendered obvious by any combination of Shibahara and Chen based on
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`the following.
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`In the rejection of claim 13 on page 8 of the Office Action, the Examinerstates the
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`following:
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`“Regarding claim 13, Shibahara in view of Chen teaches the encoder according to
`claim 1,
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`in the second quantization, each of the secondary coefficients is
`divided by a quantization step common between the secondary coefficients
`(Shibahara [0317]).”
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`Applicant notes that paragraph [0317] of Shibahara teachesthat a first partial signalis
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`multiplied by “a reciprocal mf of the quantization matrix,” where expression 19 of Shibahara
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`describes mfas follows: mf(i) = 1/ffi). Accordingly,it is noted that paragraph [0317] of
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`Shibahara teachesthat the first partial signal is divided by f(1), where i indicates a frequency
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`position in the first partial signal (See [0111] of Shibahara), and as such, Shibahara describes that
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`a plurality offare provided for yz but does not describe a common/is provided for yzz.
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`Additionally, with regard to a quantization step that is used in dividing coefficients of a
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`current block, Applicant respectfully submits that the closest teaching of Shibaharais
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`“LevelScale(i,j)” and that paragraph [0109] of Shibahara clearly states that “[t]he level scale is a
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`parameter for dividing a signal to be quantized (specifically, the second partial signal yiv’”” and
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`the second transformed output signal y2”) and corresponds to whatis called a quantization step.”
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`Accordingly, a scaling parameteris different from a quantization step. Further, by using a
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`LevelScale(i,j) in dividing coefficients of a current block, the coefficients are divided by
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`respective values according to respective positions thereof, that is, the coefficients are not
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`divided by a common value.
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`Therefore, it is respectfully submitted that Shibahara fails to teach “(i) when the
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`secondary transform is not to be applied, calculates quantized primary coefficients by performing
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`a first quantization on the primary coefficients using a quantization matrix, the quantization
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`matrix including quantization steps by which the respective primary coefficients are divided, and
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`(ii) when the secondary transform is to be applied, performs a secondary transform from the
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`primary coefficients to secondary coefficients, and calculates quantized secondary coefficients
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`by performing a second quantization on the secondary coefficients, the second quantization using
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`a quantization step by which each of the secondary coefficients is divided, the quantization step
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`being common between the secondary coefficients,” as required by the above-noted features of
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`claim 1.
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`Further, the remaining cited priorart fails to provide disclosure that would obviate the
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`above-mentioned deficiencies of Shibahara. For example, Chen fails to provide disclosure of a
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`quantization process with regard to secondary transform.
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`Additionally, although Boon (US 5,570,197), whichis cited in the rejection of claims 38
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`and 40, discloses quantized coefficients that are generated by division by a predetermined
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`integer, Boon fails to contain disclosure related to a secondary transform.
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`Assuming for the sake of argument that Shibahara and Boon are combinable, Applicant
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`notes that both ofthe first partial signal and the secondpartial signal of Shibahara are quantized
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`by being divided by a predetermined integer. It is respectfully submitted that there is no teaching
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`or suggestion in Shibahara and Boonthat one of ordinary skill in the art would have been
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`motivated to (1) when secondary transform is not to be applied, use a quantization matrix
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`including quantization steps by which the respective primary coefficients are divided and(ii)
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`whenthe secondary transform is to be applied, use a quantization step by which each ofthe
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`secondary coefficients is divided, the quantization step being common between the secondary
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`coefficients, as required by the above-noted features of claim 1.
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`In contrast to the cited prior art, the presently claimed invention requires circuitry which
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`“(1) when the secondary transform is not to be applied, calculates quantized primary coefficients
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`by performinga first quantization on the primary coefficients using a quantization matrix, the
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`quantization matrix including quantization steps by which the respective primary coefficients are
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`divided, and (ii) when the secondary transform is to be applied, performs a secondary transform
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`from the primary coefficients to secondary coefficients, and calculates quantized secondary
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`coefficients by performing a second quantization on the secondary coefficients, the second
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`quantization using a quantization step by which each of the secondary coefficients is divided, the
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`quantization step being common between the secondary coefficients.”
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`Applicant notes that, when secondary transform is not applied to the current block,it is
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`possible to quantize coefficients with varying quantization steps according to their positions in
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`the frequency domain, and when secondary transform is applied to the current block, the
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`coefficients are no longer frequency components correlated with their positions. Therefore, it is
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`sufficient to use a “quantization step being common between the secondary coefficients” for the
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`second quantization as required by the above-noted features of claim 1.
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`It is noted that this allows for an increase in coding efficiency, as “it is possible to skip a
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`process for encoding and a process for deriving a quantization matrix for the second
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`quantization” as explained in paragraph [0357] of the current application. Further, this allows to
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`optimize the quantization process depending on the application of a secondary transform on the
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`current block.
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`In view of the above, Applicant respectfully submits that any combination of Shibahara
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`and Chenfails to disclose, suggest, or otherwise render obvious the above-noted features of
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`claim 1. Accordingly, claim 1 is patentable over any combination of Shibahara and Chen.
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`Claims 2-9 and 12-15 are patentable over any combination of Shibahara and Chen based
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`at least on their dependency from claim 1.
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`Claim 16 recites features generally corresponding to the above-noted features of claim 1.
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`Accordingly, Applicant respectfully submits that any combination of Shibahara and Chenfails to
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`disclose, suggest, or otherwise render obvious these corresponding features of claim 16 for
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`reasons similar to those discussed above with respect to claim 1, and as such, claim 16 is
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`patentable over any combination of Shibahara and Chen.
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`10
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`Claim 41 was rejected under 35 U.S.C. 102(a)(1) as being anticipated by Shibahara, and
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`claims 38 and 40 were rejected under 35 U.S.C. 103 as being unpatentable over Shibahara in
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`view of Chen, and further in view of Boon (US 5,570,197). As noted above, claims 38, 40, and
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`41 have been cancelled without prejudice or disclaimer to the subject matter therein, and as such,
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`itis respectfully submitted that the above-noted rejections of claims 38, 40, and 41 are moot.
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`Il.
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`Allowable Subject Matter
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`Claims 10 and 11 were objected to as being dependent on rejected base claim 1.
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`Applicant respectfully requests that the objection to claims 10 and 11 be withdrawn based on the
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`allowability of claim 1 as discussed above.
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`IV.
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`Conclusion
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`In view of the foregoing amendments and remarks, Applicant respectfully submits that
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`claims 1-16 are clearly in condition for allowance. An early notice thereof is earnestly solicited.
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`If, after reviewing this Amendment, the Examinerbelieves that there are any issues
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`remaining which mustbe resolved before the application can be passedtoissue, it is respectfully
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`requested that the Examiner contact the undersigned by telephonein order to resolve such issues.
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`Respectfully submitted,
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`/Stephen W. Kopchik/
`2021.04.13 08:39:47 -04'00'
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`
`Stephen W. Kopchik
`Registration No. 61,215
`Attorney for Applicant
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`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
`April 13, 2021
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`The Director is hereby authorized to charge any fees which may be required, or credit any overpayment
`to Deposit Account No. 23-0975.
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`11
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