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 .
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Under Step 1 of the patent eligibility analysis, it must first be determined whether the claims are directed to one of the four statutory categories of invention. Applying Step 1 to the claims it is determined that: claims 1-10 are directed to a process; and claims 11-20 are directed to a machine.
Independent Claims
Under Step 2A Prong 1 of the patent eligibility analysis, it must be determined whether the claims recite an abstract idea that falls within one or more designated categories or “buckets” of patent ineligible subject matter that amount to a judicial exception to patentability.
The independent claims recite an abstract idea. Specifically, independent claim 1 recites an abstract idea in the limitations (emphasized):
identifying a token relating to embodied emissions for an information technology (IT) hardware component;
determining embodied emissions for the IT hardware component that have been offset, based on the token; and
recording the offset of the embodied emissions for the IT hardware component, comprising:
modifying a sticky bit for the IT hardware component,
wherein the sticky bit reflects the offset of the embodied emissions,
wherein the modification of the sticky bit is irreversible, and
wherein the sticky bit is integrated into the IT hardware component.
These limitations recite an abstract idea because these limitations encompass fundamental economic principles or practices (i.e., mitigation). These limitation’s encompass fundamental economic principles or practices (i.e., mitigation) because these limitations essentially encompass determining mitigations amounts based on carbon emissions. Claims 1, 11, and 16 recite an abstract idea.
Under Step 2A Prong 2 of the patent eligibility analysis, it must be determined whether the identified, recited abstract idea includes additional elements that integrate the abstract idea into a practical application.
The additional elements of the independent claims do not integrate the abstract idea into a practical application. Claim 1 recites the additional elements (emphasized):
identifying a token relating to embodied emissions for an information technology (IT) hardware component;
determining embodied emissions for the IT hardware component that have been offset, based on the token; and
recording the offset of the embodied emissions for the IT hardware component, comprising:
modifying a sticky bit for the IT hardware component,
wherein the sticky bit reflects the offset of the embodied emissions,
wherein the modification of the sticky bit is irreversible, and
wherein the sticky bit is integrated into the IT hardware component.
These additional elements do not integrate the abstract idea into a practical application for the following reasons. First, the additional elements of the token relating to emissions, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements are only a general link to a field of use or technological environment, see MPEP 2106.05(h) (discussing Affinity Labs). That is, although these additional elements do limit the use of the abstract idea, this type of limitation merely confines the use of the abstract idea to a particular technological environment (i.e., blockchain or distributed ledgers) and does not integrate the abstract idea into a practical application or add an inventive concept to the claims.
Second, the additional elements recording the offset of the embodied emissions for the IT hardware component and wherein the sticky bit reflects the offset of the embodied emissions, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements encompass a generic computer function of storing receiving data (e.g. storing user input), see MPEP 2106.05(f)(2) (noting the use of computers in their ordinary capacity to receive, store, or transmit data does not integrate a judicial exception into a practical application).
Third, the additional elements of the modifying a sticky bit that is irreversible and integrated into the IT hardware component, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements are only a general link to a field of use or technological environment, see MPEP 2106.05(h) (discussing Affinity Labs). That is, although these additional elements do limit the use of the abstract idea, this type of limitation merely confines the use of the abstract idea to a particular technological environment (i.e., user permissions) and does not integrate the abstract idea into a practical application or add an inventive concept to the claims.
Fourth, Claims 11 and 14 further recite "one or more computer processors; and a memory containing a program" and a "computer-readable storage medium having computer-readable program code embodied therewith", respectively. These additional elements, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. Claims 1, 11, and 16 are directed to an abstract idea.
Under Step 2B of the patent eligibility analysis, the additional elements are evaluated to determine whether they amount to something “significantly more” than the recited abstract idea (i.e., an innovative concept).
The independent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply the exception and general links to field of use. Mere instructions to apply an exception using generic computer components and general links to field of use cannot provide an inventive concept. Claims 1, 11, and 16 are not patent eligible.
Dependent Claims
The dependent claims are rejected under 101 as directed to an abstract idea for the following reasons.
Claims 2, 12 and 17 recite the same abstract idea as the independent claims because the offset comprising a portion of the emissions is a part of mitigation.
Claims 2, 12 and 17 further recites the additional elements of modifying a sticky bit that reflects the offset. These additional elements, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements are only a general link to a field of use or technological environment, see MPEP 2106.05(h) (discussing Affinity Labs). That is, although these additional elements do limit the use of the abstract idea, this type of limitation merely confines the use of the abstract idea to a particular technological environment (i.e., user permissions) and does not integrate the abstract idea into a practical application or add an inventive concept to the claims.
Claims 3, 4, 13, 14, 18, and 19 into a practical application because the additional elements are only a general link to a field of use or technological environment, see MPEP 2106.05(h) (discussing Affinity Labs). That is, although these additional elements do limit the use of the abstract idea, this type of limitation recite the additional elements of pseudo-Boolean logic and Heyting algebra. These additional elements, when considered individually or in combination, do not integrate the abstract idea merely confines the use of the abstract idea to a particular technological environment (i.e., data designs) and does not integrate the abstract idea into a practical application or add an inventive concept to the claims.
Claims 5, 15 and 20 recite the same abstract idea as the independent claims because the offset comprising all of the emissions is a part of mitigation.
Claims 5, 15 and 20 further recite the additional elements of modifying a sticky bit that reflects the offset. These additional elements, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements are only a general link to a field of use or technological environment, see MPEP 2106.05(h) (discussing Affinity Labs). That is, although these additional elements do limit the use of the abstract idea, this type of limitation merely confines the use of the abstract idea to a particular technological environment (i.e., user permissions) and does not integrate the abstract idea into a practical application or add an inventive concept to the claims.
Claims 6-8 recite the same abstract idea as the independent claims because the emissions including CO2 equivalents, relating to the various claimed processes, and being certified is a part of the mitigation.
Claims 9 and 10 recite the additional elements of using the IT hardware and using it in a cloud computing environment. These additional elements, when considered individually or in combination, do not integrate the abstract idea into a practical application because the additional elements are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claim(s) 1, 2, 5, 9-12, 15-17, and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Liu et al, US Pub. No. 2015/0350195, herein referred to as “Liu”, in view of Vangara et al, US Pub. No. 2015/0350195, herein referred to as “Vangara”.
Regarding claim 1, Liu teaches:
identifying a token relating to embodied emissions for an information technology (IT) hardware component (determines carbon balance for comparison process, ¶[0102] and Fig. 2; see also ¶[0110] discussing computer systems);
determining embodied emissions for the IT hardware component that have been offset, based on the token (adjusts token based on carbon reduction, ¶[0102] and Fig. 9; see also ¶[0053] discussing adjust token based on offset);
and recording the offset of the embodied emissions for the IT hardware component, comprising (records environmentally beneficial activity, ¶¶[0042], [0049]):
reflects the offset of the embodied emissions (tokens are adjusted to reflect offsets, ¶[0053]);
integrated into the IT hardware component (is attached to decarbonized product, ¶[0089])
However Liu does not teach but Vangara does teach:
modifying a sticky bit for the IT hardware component (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication),
wherein the modification of the sticky bit is irreversible (cannot change the metadata, ¶[0022]),
and wherein the sticky bit is integrated into the IT hardware component (authentication component is integrated, ¶[0035]).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 2, the combination of Liu and Vangara teaches all the limitations of claim 1 and Liu further teaches:
wherein the offset of the embodied emissions for the IT hardware component comprises a portion of a total quantity of embodied emissions for the IT hardware component (when carbon reduction is negative, a net amount of carbon increase has occurred, ¶[0095]),
reflects the portion of embodied emissions offset (tokens are adjusted to reflect offsets, ¶[0053]).
However Liu does not teach but Vangara does teach:
wherein the sticky bit comprises one or more of a plurality of sticky bits integrated into the IT hardware component (authentication component is integrated, ¶[0035]),
and wherein modifying the sticky bit (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 5, the combination of Liu and Vangara teaches all the limitations of claim 2 and Liu further teaches:
determining that all embodied emissions for the IT hardware component have been offset (when carbon reduction difference is positive, then a net amount of carbon reduction has been achieved with respect to these factors, ¶[0095]);
reflects that the IT hardware component is net-zero for embodied emissions determining that all embodied emissions for the IT hardware component have been offset (when carbon reduction difference is positive, then a net amount of carbon reduction has been achieved with respect to these factors, ¶[0095]).
However Liu does not teach but Vangara does teach:
and setting a further sticky bit for the IT hardware component, wherein the further sticky bit (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 9, the combination of Liu and Vangara teaches all the limitations of claim 1 and Liu further teaches:
wherein the IT hardware component relates to execution of workloads in a distributed computing system, the method further comprising: executing a first workload using the IT hardware component based on the token (performs various operations based on the token, e.g., ¶¶[0110], [0113]).
Regarding claim 10, the combination of Liu and Vangara teaches all the limitations of claim 9 and Vangara further teaches:
wherein the distributed computing system comprises a cloud computing environment, and wherein the IT hardware component is one of a plural of hardware components used in the cloud computing environment (cloud computing, e.g., ¶¶[0045], [0053]).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 11, Liu teaches:
one or more computer processors; and a memory containing a program which when executed by the one or more computer processors performs an operation, the operation comprising (processor, memory and instructions, ¶¶[0179], [0181] and Fig. 21):
identifying a token relating to embodied emissions for an information technology (IT) hardware component (determines carbon balance for comparison process, ¶[0102] and Fig. 2; see also ¶[0110] discussing computer systems);
determining embodied emissions for the IT hardware component that have been offset, based on the token (adjusts token based on carbon reduction, ¶[0102] and Fig. 9; see also ¶[0053] discussing adjust token based on offset);
and recording the offset of the embodied emissions for the IT hardware component, comprising (records environmentally beneficial activity, ¶¶[0042], [0049]):
reflects the offset of the embodied emissions (tokens are adjusted to reflect offsets, ¶[0053]);
integrated into the IT hardware component (is attached to decarbonized product, ¶[0089])
However Liu does not teach but Vangara does teach:
modifying a sticky bit for the IT hardware component (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication),
wherein the modification of the sticky bit is irreversible (cannot change the metadata, ¶[0022]),
and wherein the sticky bit is integrated into the IT hardware component (authentication component is integrated, ¶[0035]).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 12, the combination of Liu and Vangara teaches all the limitations of claim 11 and Liu further teaches:
wherein the offset of the embodied emissions for the IT hardware component comprises a portion of a total quantity of embodied emissions for the IT hardware component (when carbon reduction is negative, a net amount of carbon increase has occurred, ¶[0095]),
reflects the portion of embodied emissions offset (tokens are adjusted to reflect offsets, ¶[0053]).
However Liu does not teach but Vangara does teach:
wherein the sticky bit comprises one or more of a plurality of sticky bits integrated into the IT hardware component (authentication component is integrated, ¶[0035]),
and wherein modifying the sticky bit (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 15, the combination of Liu and Vangara teaches all the limitations of claim 12 and Liu further teaches:
determining that all embodied emissions for the IT hardware component have been offset (when carbon reduction difference is positive, then a net amount of carbon reduction has been achieved with respect to these factors, ¶[0095]);
reflects that the IT hardware component is net-zero for embodied emissions determining that all embodied emissions for the IT hardware component have been offset (when carbon reduction difference is positive, then a net amount of carbon reduction has been achieved with respect to these factors, ¶[0095]).
However Liu does not teach but Vangara does teach:
and setting a further sticky bit for the IT hardware component, wherein the further sticky bit (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 16, Liu teaches:
a computer-readable storage medium having computer-readable program code embodied therewith, the computer-readable program code executable by one or more computer processors to cause the one or more computer processors to perform an operation, the operation comprising (processor, memory and instructions, ¶¶[0179], [0181] and Fig. 21):
identifying a token relating to embodied emissions for an information technology (IT) hardware component (determines carbon balance for comparison process, ¶[0102] and Fig. 2; see also ¶[0110] discussing computer systems);
determining embodied emissions for the IT hardware component that have been offset, based on the token (adjusts token based on carbon reduction, ¶[0102] and Fig. 9; see also ¶[0053] discussing adjust token based on offset);
and recording the offset of the embodied emissions for the IT hardware component, comprising (records environmentally beneficial activity, ¶¶[0042], [0049]):
reflects the offset of the embodied emissions (tokens are adjusted to reflect offsets, ¶[0053]);
integrated into the IT hardware component (is attached to decarbonized product, ¶[0089])
However Liu does not teach but Vangara does teach:
modifying a sticky bit for the IT hardware component (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication),
wherein the modification of the sticky bit is irreversible (cannot change the metadata, ¶[0022]),
and wherein the sticky bit is integrated into the IT hardware component (authentication component is integrated, ¶[0035]).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 17, the combination of Liu and Vangara teaches all the limitations of claim 16 and Liu further teaches:
wherein the offset of the embodied emissions for the IT hardware component comprises a portion of a total quantity of embodied emissions for the IT hardware component (when carbon reduction is negative, a net amount of carbon increase has occurred, ¶[0095]),
reflects the portion of embodied emissions offset (tokens are adjusted to reflect offsets, ¶[0053]).
However Liu does not teach but Vangara does teach:
wherein the sticky bit comprises one or more of a plurality of sticky bits integrated into the IT hardware component (authentication component is integrated, ¶[0035]),
and wherein modifying the sticky bit (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Regarding claim 20, the combination of Liu and Vangara teaches all the limitations of claim 16 and Liu further teaches:
determining that all embodied emissions for the IT hardware component have been offset (when carbon reduction difference is positive, then a net amount of carbon reduction has been achieved with respect to these factors, ¶[0095]);
reflects that the IT hardware component is net-zero for embodied emissions determining that all embodied emissions for the IT hardware component have been offset (when carbon reduction difference is positive, then a net amount of carbon reduction has been achieved with respect to these factors, ¶[0095]).
However Liu does not teach but Vangara does teach:
and setting a further sticky bit for the IT hardware component, wherein the further sticky bit (modifies sticky bit, e.g., ¶[0022]; see also e.g., ¶[0040] discussing authentication).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction of Liu with the sticky bits for authentications of Vangara because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized the sticky bits would be useful for proving the carbon offsets are authentic.
Claim(s) 3, 4, 13, 14, 18 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Liu and Vangara, further in view of Hayes. "Pseudo-Boolean logic circuits." IEEE Transactions on Computers 100.7 (1986): 602-612, herein referred to as “Hayes”
Regarding claim 3, the combination of Liu and Vangara teaches all the limitations of claim 2 and does not teach but Hayes does teach:
wherein modifying the sticky bit for the IT hardware component comprises: modifying a pseudo-boolean logic circuit integrated into the IT hardware component (pseudo-boolean logic circuit, pgs. 602-603).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction with the sticky bits of Liu and Vangara with the pseudo-boolean logic circuit of Haynes because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have modified Liu and Vangara to use pseudo-boolean logic circuit for situation where they would be advantageous (e.g., where increased efficiency is desirable).
Regarding claim 4, the combination of Liu, Vangara and Hayes teaches all the limitations of claim 3 and Hayes further teaches:
wherein the pseudo-boolean logic circuit implements Heyting algebra (Heyting algebra, pgs. 603, 605).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction with the sticky bits of Liu and Vangara with the pseudo-boolean logic circuit of Haynes because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have modified Liu and Vangara to use pseudo-boolean logic circuit for situation where they would be advantageous (e.g., where increased efficiency is desirable).
Regarding claims 13, 14, 18 and 19, claims 13, 14, 18 and 19 recite similar limitations as claims 3 and 4 and accordingly are rejected for similar reasons as claims 3 and 4.
Claim(s) 6, 7, and 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Liu and Vangara, further in view of Gogerty et al, US Pub. No. 2023/0196459, herein referred to as “Gogerty”.
Regarding claim 6, the combination of Liu and Vangara teaches all the limitations of claim 1 and does not teach but Gogerty does teach:
wherein the embodied emissions comprise estimated CO2 equivalent (CO2e) emissions relating to manufacture of the IT hardware component (tracks carbon dioxide equivalent, ¶[0100]).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction with the sticky bits of Liu and Vangara with the estimated CO2 equivalent (CO2e) of Gogerty because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized users of Liu and Vangara would not only be interested in tracking carbon dioxide but would also be interested in CO2 equivalent produced.
Regarding claim 7, the combination of Liu, Vangara and Gogerty teaches all the limitations of claim 6 and Gogerty further teaches:
wherein the embodied emissions relate to all of: (i) raw material extraction, (ii) manufacture, (iii) transportation, (iv) packaging, and (v) end of life for the IT hardware component (extraction, manufacture, distribution, use and final disposition, ¶[0172]).
Further, it would have been obvious before the effective filing date of the claimed invention, to combine the proof of work for carbon reduction with the sticky bits of Liu and Vangara with the life cycle analysis of carbon dioxide emissions of Gogerty because known work in one field of endeavor may prompt variations of it for use in the same field based on design incentives, see MPEP 2143.I.F. That is, one of ordinary skill would have recognized users of Liu and Vangara would likely be interested in tracking carbon dioxide through all aspects of the product.
Regarding claim 8, the combination of Liu, Vangara and Gogerty teaches all the limitations of claim 7 and Liu further teaches:
wherein the embodied emissions are certified by a third party entity, prior to the offset (carbon credits are granted by government, ¶[0035]).
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
Campbell et al, WO 2023/034386 teaches a similar system
Quigley et al, US Pub. No. 2023/0274244 teaches a similar system
Blaikie et al, US Pub. No. 2023/0274287 teaches a similar system
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/BRENDAN S O'SHEA/Examiner, Art Unit 3626