REMARKS
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`In an Office Action dated July 20, 2023, claims 23 and 24 were rejected. Herein, claims
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`23 and 24 have been amended. No new matter has been added. Applicant respectfully requests
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`further examination and reconsideration in view of the following remarks.
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`L
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`Support for Amendment
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`Support for the amendments to the claims is found at least at FIG. 53 and paragraphs
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`[0498], [0516], and [0540] of US 2021/0037243, whichis the pre-grant publication of the instant
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`application. Accordingly, no new matter has been added.
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`II.
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`Claim Rejection under 35 U.S.C. 102
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`Claims 23 and 24 were rejected under 35 U.S.C. 102(a)(1) as being anticipated by Hsieh
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`et al. (US 2018/0103252). Applicant respectfully requests reconsideration of the above-noted
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`rejection in view ofthe following.
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`Claim 23 recites the following features:
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`(i) when a size of the current blockis a first block size, the second transform is applied to
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`a first sub-block having a first sub-block size in the current block using a transform scheme of
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`the second transform is selected from a first group of candidates,
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`(ii) when the size of the current block is a second block size different from the first block
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`size, the second transform is applied to a second sub-block havingthe first sub-block size in the
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`current block using the transform schemeof the second transform is selected from a second
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`group of candidates,
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`the first group of candidates includesa first transform scheme which generatesa first
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`numberof transform coefficients using a first transform matrix, and
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`the second group of candidates includes a second transform scheme which generates a
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`second numberof transform coefficients using the first transform matrix, the first numberis
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`smaller than the second number.
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`Applicant respectfully submits that the above-noted features of claim 23 are not
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`disclosed, suggested, or otherwise rendered obvious by Hsieh based on the following.
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`

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`Referring to paragraphs [0162], [0164], [0165], [0168] and [0170] of Hsieh, the
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`Examinerstates the following in the “Response to Arguments” section on page 4 of the Office
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`Action:
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`“Thus, it is clear that the transforms are applied differently under different block
`size parameters and Hsieh et al.
`teaches selecting between and performing a
`second transform in a 4x4 block size and an 8x8 block size, each with associated
`group of candidates,
`the number resultant coefficients in an 8x8 block being
`higher than that in a 4x4 block.”
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`However, in the portions of Hsieh cited by the Examiner, the numberof transform
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`coefficients obtained by performing a second transform on an 88 sized block is compared with
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`the numberof transform coefficients obtained by performing the second transform on a 4*4
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`sized block.
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`Applicantnotes that this is clearly different from comparing numbers of transform
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`coefficients, each of which is obtained by performing a second transform using the same
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`transform matrix on sub-blocks of the same size, as required by the above-noted features of
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`claim 23.
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`As described in paragraph [0498] of US 2021/0037243, an encoder performs a second
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`transform using a basis selected from candidates such as 4~4 basis A, 4*4 basis B, 4*4 basis C,
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`8x8 basis D, 8x8 basis E, and 8x8 basis F. Asillustrated in FIG. 53, even when the block size of
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`a current block to be processedis different (e.g., 4x4 and 8x8), the second transform can be
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`applied to sub-blocks of the samesize (e.g., 4x4). Moreover, even when the second transform is
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`applied using a commonbasis, that is, a commontransform matrix, since some bases have
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`transform characteristics such that a portion of transform coefficient values are forced to 0 and
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`other bases do not have such transform characteristics, this results in different numbers of
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`coefficients between blocksafter the second transform process, as described in paragraph [0516]
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`of US 2021/0037243.
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`In other words, according to the claimed invention, even when performing, on blocks
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`having different block sizes, a second transform process using the same transform matrix for
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`

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`sub-blocks of the same size, different numbers of transform coefficients are obtained after the
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`second transform process.
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`Although Hsieh teaches performing a second transform on each of blocks having the
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`block sizes of 4x4 and 88, Hsieh fails to disclose that when applying a second transform to sub-
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`blocks having the same size, using the same transform matrix, the numbers of transform
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`coefficients obtained by the second transform are different, as required by the above-noted
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`features of claim 23.
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`Accordingly, Hsieh necessarily fails to teach “(i) when a size of the current block is a
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`first block size, the second transform is applied to a first sub-block having a first sub-block size
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`in the current block using a transform scheme of the second transform is selected from a first
`99 6¢
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`group of candidates,”
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`“(11) when the size of the current block is a second blocksize different
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`from thefirst block size, the second transform is applied to a second sub-block havingthefirst
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`sub-block size in the current block using the transform schemeof the second transform is
`99 66
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`selected from a second group of candidates,”
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`“the first group of candidates includesa first
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`transform scheme which generatesa first number of transform coefficients using a first transform
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`matrix,” and “the second group of candidates includes a second transform scheme which
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`generates a second numberof transform coefficients using the first transform matrix, the first
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`numberis smaller than the second number,” as required by the above-noted features of claim 23.
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`Additionally, in the “Response to the Arguments” section on page 4 of the Office Action,
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`the Examinerstates “[f]urthermore, the transform basis is not well defined by the claim
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`language, and the rotational transform and mode-dependent non-separable secondary transform
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`are both interpreted to be transform bases applied to different sizes with different numbers of
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`resulting coefficients.”
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`Applicant notes that claim 23 has been amendedto replace the term “transform basis”
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`with --transform matrix--, and as such, the presently claimed invention has been amended to
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`clarify that what is commonly applied to blocks having different sizes is neither ROT nor
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`MDNSST.
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`

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`In view of the above, Applicant respectfully submits that Hsieh fails to disclose, suggest,
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`or otherwise render obvious the above-noted features of claim 23. Accordingly, claim 23 is
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`patentable over Hsieh.
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`Claim 24 recites features generally corresponding to the above-noted features of claim
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`23. Accordingly, Applicant respectfully submits that Hsieh fails to disclose, suggest, or
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`otherwise render obvious these corresponding features of claim 24 for reasons similar to those
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`discussed above with respect to claim 23, and as such, claim 24 is patentable over Hsieh.
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`I.
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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 23 and 24 are clearly in condition for allowance. An early notice thereofis earnestly
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`solicited.
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`If, after reviewing this Amendment, the Examinerbelieves that there are any issues
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`remaining which must be resolved before the application can be passedto issue, 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,
`/Stephen Kopchik/
`2023.10.14 17:46:01 -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
`October 16, 2023
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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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