Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 01/05/2026 has been entered. Claims 1, 6, 9, 10, and 13 are amended. Claim 8 is cancelled. Claims 1-7 and 9-15 are currently pending in the application.
Claim Objections
Claim 1 and dependents thereof are objected to because of the following informality: In Claim 1, the recitation of “implementing an assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database” reads awkwardly. “Implementing” is generally defined as the act of executing or carrying out … a process, a plan, steps, etc. The instant specification, as published, uses the above noted common definition (see at least ¶ 40: the assessment device comprising means for implementing the steps of the assessment method; ¶ 118: means for implementing the steps of the assessment method 100. The assessment device 200 comprises a module 204 for collecting endogenous data and exogenous data, able to implement the collection step 102, a data processing module 206 configured to correlate collected endogenous data and exogenous data and able to implement the correlation step 104, a data processing module 208 configured to analyze observable behavior data based on trigger event parameters and action parameters, and able to implement the analysis step 106, and a data processing module 210 configured to assess the behavior of said at least one operator and assess technical and non-technical skills of said at least one operator, and able to implement the steps 108 of assessing behavior and 110 of assessing each skill; ¶ 118: means for implementing the steps of the assessment method 100; ¶ 120: implementing the display step 112 ….implementing the storage step 114). Emphasis added. To avoid any claim ambiguity, the claim could be amended to recite: “implementing the assessment method using an assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database”. The claim will be interpreted as such for purpose of examination. Appropriate correction is required.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-7 and 9-15 are rejected under 35 U.S.C. 101 because the claimed invention is directed to abstract idea without significantly more.
In regard to independent claim 1, analyzed as representative claim:
Step 1: Statutory Category?
Independent Claim 1 recites “A method for assessing technical and non-technical skills of at least one operator in a mission or training situation on a real or simulated platform, the assessment method comprising:”. Independent Claim 1 falls within the “process” category of 35 U.S.C. § 101.
Step 2A – Prong 1: Judicial Exception Recited?
The Independent Claim 1/Revised 2019 Guidance Table below identifies in italics the specific claim limitations found to recite an abstract idea and in bold the additional (non-abstract) claim limitations that are generic computer components.
Independent Claim 1
Revised 2019 Guidance
A method for assessing technical and non-technical skills of at least one operator in a mission or training situation on a real or simulated platform, the assessment method comprising: implementing the assessment method using an assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database
A process (method) is a statutory
subject matter class. See 35 U.S.C.
§ 101 (“Whoever invents or
discovers any new and useful
process, machine, manufacture, or
composition of matter, or any new
and useful improvement thereof,
may obtain a patent therefor, subject
to the conditions and requirements of
this title.”).
The “assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database” are additional non-abstract limitations – generic components.
Abstract: “assessing technical and non-technical skills of at least one operator in a mission or training situation on a real or simulated platform …” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that a trainer/coach could assess the at least one operator through visual and/or verbal interactions.
[L1] a step of collecting endogenous data with the collection component, the collection component implementing at least one sensor configured and/or operable to sense physical manifestations and physical parameters of said at least one operator during a mission or training session, and
The “collection component” and “at least one sensor” are additional non-abstract limitations – generic components.
Collecting endogenous data is an additional element that adds insignificant extra-solution activity to the judicial exception, e.g., mere data gathering. See January 2019 Memorandum, 84 Fed. Reg. 55, n. 31.
Abstract: “collecting endogenous data … relating to physical manifestations and/or physical parameters of said at least one operator during a mission or training session” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that the person/educator could collect data on the at least one operator visually and/or by hearing the information.
[L2] collecting exogenous data from a platform with the collection component, the exogenous data relating to a context of said mission or said training session on the platform, wherein the platform comprises a real platform or a simulated platform,
The “platform that comprises a real platform or a simulated platform” are additional non-abstract limitations – generic components.
Collecting endogenous data is an additional element that adds insignificant extra-solution activity to the judicial exception, e.g., mere data gathering. See January 2019 Memorandum, 84 Fed. Reg. 55, n. 31.
Abstract: “collecting exogenous data … relating to a context of said mission or said training session” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that the person/educator could collect data on the at least one operator visually and/or by hearing the information.
[L3] computer-implemented steps, performed by the assessment device, of: correlating the collected data with the first data processing component in order to link the endogenous data to the exogenous data;
The “assessment device” and “first data processing component” are additional non-abstract limitations – generic components.
Abstract: “correlating the collected data in order to link the endogenous data to the exogenous data …” could be performed alternatively as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that a trainer/coach could mentally and/or in writing correlate data.
[L4] detecting observable behavior data using the correlated data, an observable behavior datum comprising at least one parameter defining a trigger event parameter and one parameter defining an action parameter
Abstract: “detecting observable behavior data using the correlated data, an observable behavior datum …” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that the person/educator could collect data on the at least one operator visually and/or by hearing the information.
[L5a] analyzing the observable behavior data in predefined analysis sequences, with the second data processing component, each predefined analysis sequence being specific to one of a plurality of technical skills and a plurality of non-technical skills to be assessed, and comprising at least one trigger event parameter that represents an action that is at an origin of a potential reaction of the at least one operator and one action parameter characterizing an expected observable behavior according to a predefined situation,
The “second data processing component” is an additional non-abstract limitation – generic component.
Abstract: “analyzing the observable behavior data in predefined analysis sequences … each predefined analysis sequence being specific to a technical and non-technical skill to be assessed …” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that the person/educator could collect data on the at least one operator visually and/or by hearing the information.
[L5b] the analysis generating a measurement indicator for each observed behavior;
“…generating a measurement indicator for each observed behavior ” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that the person/educator could generate data verbally and/or in writing. See January 2019 Memorandum, 84 Fed. Reg. at 52.
[L6a] assessing the observed behaviors of said at least one operator with the third data processing component,
The “third data processing component” is an additional non-abstract limitation – generic component.
Abstract: “assessing the observed behaviors of said at least one operator” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that a trainer/coach could assess the at least one operator through visual and/or verbal interactions. See January 2019 Memorandum, 84 Fed. Reg. at 52.
[L6b] said assessment by the third data processing component consisting in comparing an observed behavior with an expected predefined reference behavior;
The “third data processing component” is an additional non-abstract limitation – generic component.
Abstract: “comparing an observed behavior with an expected predefined reference behavior” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that a trainer/coach could compare data through visual and/or audible observation(s). See SmartGene, Inc. v. Advanced Biological Labs., SA, 555 F. App’x 950, 955 (Fed. Cir. 2014) (“[T]he claim at issue here involves a mental process excluded from section 101: the mental steps of comparing new and stored information and using rules to identify medical options” …
[L6c] the expected predefined reference behavior being stored in the correspondence database and the third data processing component
The “correspondence database” and the “third data processing component” are additional non-abstract limitations – generic components.
Storing data is an additional element that
adds insignificant extra-solution activity to
the judicial exception, e.g., mere data
gathering. See January 2019
Memorandum, 84 Fed. Reg. 55, n. 31.
[L6d] and the third data processing component utilizing the expected predefined reference behavior for comparing to the observed behavior;
The “third data processing component” is an additional non-abstract limitation – generic component.
Abstract: “utilizing the expected predefined reference behavior for comparing to the observed behavior” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that a trainer/coach could compare data through visual and/or audible observation(s). See SmartGene, Inc. v. Advanced Biological Labs., SA, 555 F. App’x 950, 955 (Fed. Cir. 2014) (“[T]he claim at issue here involves a mental process excluded from section 101: the mental steps of comparing new and stored information and using rules to identify medical options” …
[L7] assessing each technical skill and non-technical skill of said at least one operator on a basis of results of the behavior assessments
Abstract: “assessing each technical skill and non-technical skill of said at least one operator on a basis of results of the behavior assessment” could be performed as a mental process, i.e., concept performed in the human mind or using pencil and paper (including an observation, evaluation, judgment, opinion) and a “[c]ertain method[] of organizing human activity. . . managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)” to the extent that a trainer/coach could compare data through visual and/or audible observation(s). See SmartGene, Inc. v. Advanced Biological Labs., SA, 555 F. App’x 950, 955 (Fed. Cir. 2014) (“[T]he claim at issue here involves a mental process excluded from section 101: the mental steps of comparing new and stored information and using rules to identify medical options” …
[L8] and providing at least a portion of an assessment of the technical skill and/or the non- technical skill to said at least one operator and/or an instructor by displaying the assessments of the technical and non-technical skills with the display device, wherein the at least one sensor comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors.
The “display device” and “at least one sensor comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors” are additional non-abstract limitations – generic components.
Providing data by displaying the data is an additional element that adds insignificant extra-solution activity to the judicial exception, e.g., mere data presentation. See January 2019 Memorandum, 84 Fed. Reg. 55, n. 31.
The published Specification discloses “[T]he invention proposes a device and a method for precisely and succinctly assessing the skills of an operator or of a team of operators in a training situation or in a real or simulated mission situation” (¶ 2). Individual or group training and assessment have long been performed by humans. Thus, other than reciting the additional non-abstract limitations of the “assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database”, “at least one sensor that comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors”, “platform that comprises a real platform or a simulated platform” noted in the Independent Claim 1/Revised 2019 Guidance Table above, nothing in the claim precludes the steps from practically being performed by a human, in the mind, and/or using pen and paper. The mere nominal recitation of the additional non-abstract limitations noted above does not take the claim out of the method of organizing human activity and mental processes groupings. Accordingly, the claim recites a judicial exception (Step 2A, Prong One: YES).
Step 2A – Prong 2: Integrated into a Practical Application?
The body of the claim, as noted in the Independent Claim 1/Revised 2019 Guidance Table above, recites the additional limitation of the “assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database”, “at least one sensor that comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors”, “platform that comprises a real platform or a simulated platform”. The published Specification provides supporting exemplary descriptions of generic computer components: at least ¶ 24: computer-implemented steps, performed by data processing modules…; ¶ 40:… a device for assessing technical and non-technical skills of at least one operator in a training situation on a real or simulated platform…; ¶ 37: predefined sequences being contained in a correspondence database…; ¶ 42 program is executed on a computer; ¶ 79: The predefined sequences are contained in a correspondence database. This correspondence database thus comprises the predefined analysis sequences presenting observable behavior data known to those skilled in the art, as well as their assigned measurable and detectable physical manifestation…; ¶ 118:… invention also proposes a device 200, shown in FIG. 3, for assessing technical and non-technical skills of at least one operator in a training situation on a real or simulated platform 200…; ¶ 120:… assessment device 200 may thus comprise a display module 212 for implementing the display step 112 and a storage module 214 for implementing the storage step 114. The storage module 214 may be a physical module present in the assessment device 200 or be a digital module distributed on an Internet server, receiving and transmitting its data using an Internet network; ¶ 122:… a computer program product comprising code instructions for performing the data processing steps of the assessment method 100 when said program is executed on a computer; ¶ 123:… invention may be implemented by various means, for example by hardware, software, or a combination thereof; ¶ 124:… program code typically comprises computer-readable instructions that reside, at various times, in various memory and storage devices in a computer and that, when they are read and executed by one or more processors in a computer, prompt the computer to perform the operations necessary to carry out the operations and/or elements specific to the various aspects of the embodiments of the invention. The lack of details about the recited additional elements indicates that these additional elements are generic, or part of generic computer elements performing generic computer-implemented steps. The claimed limitations of “collecting”, “collecting”, “correlating”, “detecting”, “analyzing”, “generating”, “assessing”, “assessing”, “storing”, “assessing” and “providing” as recited do not purport to improve the functioning of the “assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database”, “at least one sensor that comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors”, “platform that comprises a real platform or a simulated platform”, do not improve the technology of the technical field, and do not require a “particular machine.” Rather, they are performed using generic computer components. Further, the claim as a whole fails to effect any particular transformation of an article to a different state. The recited steps in the claim fail to provide meaningful limitations to limit the judicial exception. In this case, the claim merely uses the claimed computer elements as a tool to perform the abstract idea.
Considering the elements of the claim both individually and as “an ordered combination” the functions performed by the computer system at each step of the process are purely conventional. Each step performed in the claim does no more than require a generic computer to perform a generic computer function. Thus, the claimed elements have not been shown to integrate the judicial exception into a practical application as set forth in the Revised Guidance which references the Manual of Patent Examining Procedure (“MPEP”) §§ 2106.04(d) and 2106.05(a)–(c) and (e)–(h). Because the abstract idea is not integrated into a practical application, the claim is directed to the judicial exception. (Step 2A, Prong Two: NO).
Step 2B: Claim provides an Inventive Concept?
As discussed with respect to Step 2A Prong Two, the additional elements in the claim amount to no more than mere instructions to apply the exception using generic computer components. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using generic computer components cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Because the published Specification, as noted above (¶¶ 24, 37, 40, 42, 79, 118, 120, 122, 123, 124) describes the “assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database”, “at least one sensor that comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors”, “platform that comprises a real platform or a simulated platform” in general terms, without describing the particulars, the claim limitations may be broadly but reasonably construed as reciting conventional computer components and techniques, particularly in light of the published Specification sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. § 112(a). See MPEP 2106.05(d), as modified by the USPTO Berkheimer Memorandum. Furthermore, the Berkheimer Memorandum, Section III (A)(1) explains that a specification that describes additional elements “in a manner that indicates that the additional elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. § 112(a)” can show that the elements are well understood, routine, and conventional); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1331 (Fed. Cir. 2017) (“The claimed mobile interface is so lacking in implementation details that it amounts to merely a generic component (software, hardware, or firmware) that permits the performance of the abstract idea, i.e., to retrieve the user-specific resources.” The generic description of “assessment device that comprises a collection component, a first data processing component, a second data processing component, a third data processing component, a display device, and a correspondence database”, “at least one sensor that comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors”, “platform that comprises a real platform or a simulated platform” indicates the steps are well-known enough that no further description is required for a skilled artisan to understand the process and that these computer components are all used in a manner that is well-understood, routine, and conventional in the field. In particular, the recited data gathering (i.e., [L1] “collecting endogenous data”; [L2] “collecting exogenous data”; [L6c] storing data) and data presentation (i.e., [L8] “providing at least a portion of an assessment …to said at least one operator and/or an instructor”) are nothing more than well-understood, routine, and conventional activity because it is not distinguished from the generic, conventional data gathering and data presentation with a computer. See Elec. Power Grp., 830 F.3d at 1356 (claims to gathering, analyzing, and displaying data in real time using conventional, generic technology do not have an inventive concept). Hence, the additional elements are generic, well-known, and conventional computing elements. The use of the additional elements either alone or in combination amounts to no more than mere instructions to apply the judicial exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept, and thus the claims are patent ineligible. (Step 2B: NO).
In regard to independent Claim 10:
Independent claim 10 is a device for assessing technical and non-technical skills of at least one operator in a training situation on a real or simulated platform, which falls within the “machine” category of 35 U.S.C. § 101. The device for assessing technical and non-technical skills of at least one operator in a training situation on a real or simulated platform is claimed as comprising means for implementing the steps of the assessment method as claimed in claim 1. As a result, independent claim 10 is rejected similarly to representative independent Claim 1.
In regard to independent Claim 11:
Independent claim 11 is a flight simulator, which falls within the “machine” category of 35 U.S.C. § 101. The flight simulator is claimed as comprising an assessment device as claimed in claim 10. As a result, independent claim 11 is rejected similarly to independent claim 10 which is rejected similarly representative independent Claim 1.
In regard to independent Claim 12:
Independent claim 12 is a computer program product… which falls within the “product” category of 35 U.S.C. § 101. The computer program product is claimed as comprising code instructions for performing the steps of the method as claimed in claim 1 when said program is executed on a computer. As a result, independent claim 12 is rejected similarly to independent claim 10 which is rejected similarly to representative independent Claim 1.
In regard to the dependent claims:
Dependent claims 2-7, 9 and 13-15 include all the limitations of independent claim 1 from which they depend and as such recite the same abstract idea(s) noted above for claim 1. None of the additional claim activities is used in some unconventional manner nor does any produce some unexpected result. An invocation to use known technology in the manner it is intended to be used for its ordinary purpose is both generic and conventional. As per MPEP §§ 2106.05(a)–(c), (e)–(h), none of the limitations of claims 2-7, 9 and 13-15 integrates the judicial exception into a practical application. While dependent claims 2-7, 9 and 13-15 may have a narrower scope than the representative claim, no claim contains an “inventive concept” that transforms the corresponding claim into a patent-eligible application of the otherwise ineligible abstract idea(s). Therefore, dependent claims 2-7, 9 and 13-15 are not drawn to patent eligible subject matter as they are directed to (an) abstract idea(s) without significantly more.
Response to Arguments
Claim Rejections - 35 U.S.C. § 112
The previous claim rejections under 35 U.S.C. § 112(b) are withdrawn in view of Applicant’s amendment.
Claim Rejections - 35 U.S.C. § 101
Applicant essentially asserts that “the claims are patent eligible consistent with Contour IP Holding LLC v. GoPro, Inc.”. Applicant’s arguments have been fully considered but they are not persuasive.
Contrary to Applicant’s remark that “[T]he claims are directed to a technological solution to a technological problem”, the issue that “the prior art approaches include flaws that may subsequently introduce gaps in the assessment and the work of, for example the skills of pilots, who could in turn jeopardize the safety of flight operations” (¶ 15) is not a problem rooted in technology, but rather “relates to the field of assessing the flying skills of a pilot and/or of a crew in a simulation or training situation on a dedicated platform” (¶ 2) which have long been performed by human instructors, and, as such, a problem that existed well before the advent of computers and the Internet.
Applicant’s reference to Contour IP Holding LLC v. GoPro, Inc. is also misplaced because the claims in Contour “require[d] specific, technological means—parallel data stream recording with the low-quality recording wirelessly transferred to a remote device” that “in turn provide[d] a technological improvement to the real time viewing capabilities of a POV camera’s recordings on a remote device.” See Contour, 113 F.4th at 1380 81. The Contour claims “enable[d] the claimed POV camera to ‘operate differently than it otherwise could’” by “by both recording multiple video streams in parallel and wirelessly transferring only one video stream, a lower quality stream, to a remote device.” Id. In contrast to the claims in Contour, the instant specification discloses that the additional claim elements, namely the “at least one sensor comprises one or more image sensors, audio sensors, manipulandum sensors and/or physiological sensors”, “platform comprises a real platform or a simulated platform”, “data processing modules” and “correspondence database” encompass generic computer components because they are described and claimed at a high level of generality. See Spec. ¶¶ 24, 37, 40, 42, 79, 118, 120, 122, 123, 124. The focus of Applicant’s representative claim 1 is on collecting and analyzing data to display additional data which is an abstract idea, as claimed, without any technical implementation details of the steps performed. Hence, contrary to Applicant’s arguments, the additional claim elements do not operate differently than they otherwise could. The Federal Circuit has consistently held that the concepts of collecting data, analyzing data, and displaying results of the collection and analysis are abstract ideas. See, e.g., Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1354 (Fed. Cir. 2016) (characterizing collecting information, analyzing information, and presenting the results of collecting and analyzing information, without more, as matters within the realm of abstract ideas).
In light of the foregoing, the Examiner maintains that each of Applicant’s claims 1-7, 9 and 13-15 considered as a whole, is directed to a patent-ineligible abstract idea that is not integrated into a practical application, and does not include an inventive concept.
Claim Rejections - 35 U.S.C. § 103
The previous rejections under 35 USC § 103 are withdrawn in view of Applicant’s amendment and arguments.
Conclusion
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/EDDY SAINT-VIL/Primary Examiner, Art Unit 3715