DETAILED ACTION
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 .
This action is in response to the Amendment filed on 1/26/2026.
Claims 21-40 are pending. Claim 21, 36, 40 have been amended. Claims 1-120 have been cancelled.
Claim Rejections - 35 USC § 103
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) 21, 23-27, 29- 30, 34 is/are rejected under 35 U.S.C. 103 as being unpatentable over Rodrigues et al. (US 20080291449 A1, hereinafter Rodrigues), in view of (Colbert et al , BRDF,Shop Creating Physically Correct Bidirectional Reflectance Distribution Functions , 200602 , IEEE, hereinafter Colbert).
Regarding Claim 21, Rodrigues teaches a computer system for dynamically displaying multiple physical based renders, comprising: one or more processors (Rodrigues, Paragraph [0130], "the system comprises a computing device (80); a display devise (85), such as a monitor screen; a database (105); one or more data input devices (81)" <read on one or more processors>; Paragraph [0065), "A computing device used herein refers to a desktop computer, a laptop computer, a pocket PC, a personal digital assistant (PDA), a handheld electronic processing device, a smart phone that combines the functionality of a PDA and a mobile phone, an iPod, an iPod/MP Player, or any other electronic devices that can process information automatically" <read on one or more processors>); and one or more computer-readable media having stored thereon executable instructions that when executed by the one or more processors configure the computer system to (Rodrigues, Paragraph [0063], "The database can be a set of electronic documents, photographs, images, diagrams, or drawings, residing in a computer readable storage media that can be searched and retrieved):[AltContent: ] display, concurrently, a plurality of rendered physical based renders (Rodrigues, Paragraph [0082], "either one at a time or a plurality of images displayed simultaneously, on a display device, such as a handheld display device, for example a PDA, a laptop or a tablet computer" <read on display, concurrently, a plurality of rendered physical based renders>; Rodrigues, Fig. 6, "Schematic presentation of images of a target coating and one or more matching coatings displayed close to each other" and "Schematic presentation of images displayed immediately adjacent to each other so that one image can have common boarders with a plurality of other images" <read on display concurrently a plurality of rendered physical based renders>);
each physical based render depicting a digital representation of a particular material with a coating applied thereon (Rodrigues, Paragraph [0074], "individual images are generated (106) based on the color and appearance characteristics interrelated to each of the preliminary matching formulas and stored in the database {105), herein referred to as individual matching images" <read on each physical based render depicting a digital representation of a particular material>; "appearance characteristics include, but not limited to, texture, metallic, pearlescent effect, gloss, distinctness of image, flake appearances such as texture, sparkle, glint and glitter as well as the enhancement of depth perception in the coatings imparted by the flakes" <read on digital representation of a particular material with a coating applied thereon>; [0049], Fig. 3A, "Images of a target coating and a matching coating are shown side by side ... Images represent colors and flake appearances of the coatings in a curved view" <read on digital representation of a particular material with a coating applied thereon>); each physical based render within the plurality of rendered physical based renders is selected based upon a predetermined characteristic that is shared by each physical based render (Rodrigues, Paragraph [0073], "one or more preliminary matching formulas from a database are retrieved (104) that match the OEM paint code, the model year, the manufacturing site information, and optionally the manufacturing date" <read on selected based upon a predetermined characteristic that is shared by each physical based render>; [0074], "individual images are generated (106) based on the color and appearance characteristics interrelated to each of the preliminary matching formulas" <read on predetermined characteristic that is shared by each physical based render>);
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Rodrigues does not explicitly disclose but Colbert teaches wherein each physical based render is generated by a physically based rendering engine using reflectance data associated with the particular material, the reflectance data comprising at least one of a bidirectional reflectance distribution function or a bidirectional texture function (Colbert, Page 30, "We present a novel and intuitive approach for material design through direct control of the material's bidirectional reflectance distribution function (BRDF) via a series of brush strokes" <read on reflectance data comprising a bidirectional reflectance distribution function>; Colbert, Page 30, "we impose the requirement of a physically correct mathematical model to make the BRDFs compatible with physically based rendering techniques" <read on physically based rendering engine using reflectance data>; Colbert, Page 33, "the actual highlights on the canvas are created by rendering the canvas geometry with the underlying BRDF" <read on generated by a physically based rendering engine using reflectance data associated with the particular material>); display a set of user interface elements, each element in the set of user interface elements being configured to adjust a material attribute associated with the plurality of rendered physical based render (Colbert, Page 33, "We provide a small set of brushes for quick and intuitive development of highlights. The modify brush ... adjusts the size of an existing highlight on the canvas and thereby controls the roughness of the material <read on material attribute associated with the plurality of rendered physical based renders>. The streaking brush ... extends a highlight to any given orientation and thus controls the direction of anisotropy for the material <read on material attribute associated with the plurality of rendered physical based renders>. The intensify brush and the deintensify brush ... modify the albedo, or reflectance value, of a highlight <read on material attribute associated with the plurality of rendered physical based renders>"); receive a command, from a user interface element within the set of user interface elements, the command configured to adjust a specific material attribute (Colbert, Page 33, "The modify brush ... adjusts the size of an existing highlight on the canvas and thereby controls the roughness of the material <read on specific material attribute>"; Colbert, Page 33, "The streaking brush ... extends a highlight to any given orientation and thus controls the direction of anisotropy for the material <read on specific material attribute>"); and adjust the specific material attribute on each physical based render within the plurality of rendered physical based renders (Colbert, Page 31, "a novel, efficient mapping of user interaction to parameters of this model" <read on adjust the specific material attribute on each physical based render>; Colbert,[AltContent: ] Page 33, "adjusts the size of an existing highlight on the canvas and thereby controls the roughness of the material <read on adjust the specific material attribute on each physical based render within the plurality of rendered physical based renders>"; Colbert, Page 34, "we vectorize each importance sample calculation by computing four sample rays at the same time. We also use approximately eight samples per pixel per BRDF lobe" <read on adjust the specific material attribute on each physical based render within the plurality of rendered physical based renders>).
[AltContent: ]Colbert and Rodrigues are analogous since both are dealing with computer-based visualization of material appearance for the purpose of matching or refining the appearance. Rodrigues provided a way of generating and displaying multiple candidate coating images to choose the best match. Colbert provided a way of interactively editing appearance parameters and immediately visualizing the resulting material behavior. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate the interactive appearance-adjustment interface taught by Colbert into the multi-image comparison workflow of Rodrigues such that a user can modify the material attributes of the displayed candidates during selection. The motivation is to improve the user's ability to judge and select the best match in color and appearance.
Regarding Claim 23, the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches wherein the predetermined characteristic comprises a model year of automobiles (Rodrigues, Paragraph [0005], “Additional information further defining the matching coatings resulted from the matching coating compositions is associated to each formula which helps the refinisher define which is the best match for the vehicle of that … model year”).
Regarding Claim 24. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches wherein the predetermined characteristic comprises a shared make of automobile attribute (Rodrigues, Paragraph [0005], “Additional information further defining the matching coatings resulted from the matching coating compositions is associated to each formula which helps the refinisher define which is the best match for the vehicle of that make”).
Regarding Claim 25. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches The combination further teaches wherein the material attribute comprises an environmental attribute variable (Cobert, Page 31, “Natural environment to light an arbitrary mesh…Page 32, Fig. 1, “The interface layout of BRDF-Shop consists of … a naturally lit object”).
Cobert and Rodrigues are analogous since both of them are dealing with computer-based visualization of material appearance for the purpose of matching or refining the appearance. Rodrigues provided a way of generating and displaying realistic coating images derived from appearance data for visual selection. Cobert provided a way of simulating and adjusting environmental lighting conditions in a physically-based renderer to alter the perceived look of a material. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate environmental-lighting variable taught by Cobert into Rodrigues such that the user could adjust environmental parameters when viewing the plurality of rendered coatings. The motivation is to let users more accurately judge coating appearance under differing lighting environments.
Regarding Claim 26. the combination of Rodrigues and Cobert teaches the invention in Claim 25.
The combination further teaches wherein the executable instructions include instructions that are executable to configure the computer system to create a custom environmental attribute variable (Rodrigues, Paragraph [0085], “The color data can be obtained by measuring reflectance of a target coating using a color measurement device,” “Color data may include spectral characteristics such as chroma, hue, lightness, darkness, and the like” [0005], “The paint code is used to identify all the different aftermarket refinish matching coating compositions and corresponding coating formulas created for that paint code”).
Regarding Claim 27. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches wherein the material attribute comprises a chroma variable (Rodrigues, Paragraph [0084], “such as a colorimeter, a spectrophotometer, or a goniospec goniospec-trophotometer. Color data may include spectral characteristics such as chroma, hue, lightness, darkness, and the like”).
Regarding Claim 29. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches wherein the material attribute comprises a coarseness or sparkle variable (Rodrigues, Paragraph [0003], “Metallic flakes, such as aluminum flakes are commonly used to produce coatings having flake appearances such as texture, sparkle, glint and glitter as well as the enhancement of depth perception in the coatings imparted by the flakes”).
Regarding Claim 30. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches wherein each physical based render comprises a stack of coatings (Rodrigues, Paragraph [0003], “Surface coatings such as monocoat, clearcoat/colorcoat, and tricoat”; it is noted clearcoat/colorcoat is a two-layer system (color/base + clear) and tricoat, “Metallic flakes, such as aluminum flakes are commonly used to produce coatings having flake appearances such as texture, sparkle, glint and glitter as well as the enhancement of depth perception in the coatings imparted by the flakes).
Regarding Claim 34. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination further teaches wherein the executable instructions include instructions that are executable to configure the computer system to communicate a particular request to a material creation server (Rodrigues, Paragraph [0065], “a client computer that communicates with a host computer in a multi-computer client-host system… A computing device can also be configured to be coupled with a data input or output device”).
Regarding Claim 36, it recites limitations similar in scope to the limitations of Claim 21 but as a method and the combination of Rodrigues and Cobert teaches all the limitations as of Claim 21. Therefore is rejected under the same rationale.
Regarding Claim 37, it recites limitations similar in scope to the limitations of Claim 25 and therefore is rejected under the same rationale.
Regarding Claim 37, it recites limitations similar in scope to the limitations of Claim 25 and therefore is rejected under the same rationale.
Regarding Claim 40, it recites limitations similar in scope to the limitations of claim 21 and the combination of Rodrigues and Cobert teaches all the limitations as of Claim 21. And Rodrigues discloses these features can be implemented on a computer readable storage medium (Rodrigues, Paragraph [0009]-[0013], [0063], This invention is directed to a system … said system comprising: … a database. The database can be a set of electronic documents, photographs, images, diagrams, or drawings, residing in a computer readable storage media that can be searched and retrieved).
Claim(s) 22 is/are rejected under 35 U.S.C. 103 as being unpatentable over Rodrigues et al. (US 20080291449 A1, hereinafter Rodrigues), in view of (Colbert et al , BRDF,Shop Creating Physically Correct Bidirectional Reflectance Distribution Functions , 200602 , IEEE, hereinafter Colbert) as applied to Claim 21 above and further in view of Van Renterghem et al. (WO2016157148A1, hereinafter Van).
Regarding Claim 22 the combination of Rodrigues and Cobert teaches the invention with predetermined characteristic in Claim 21.
The combination further teaches wherein the predetermined characteristic comprises a shared characteristic (Rodrigues, Paragraph [0072], “identification information of a vehicle is obtained … wherein said identification information comprises model year, manufacturing site information” [0073]-[0074], “one or more preliminary matching formulas… that match the OEM paint code, the model year, the manufacturing site information….generated…individual matching images… based on the color and appearance characteristics… interrelated to each of the preliminary matching formulas”; it is noted since every displayed candidate image are in the comparison set back to the formulas that all match the EM paint code…i.e. a shared predetermined characteristics).
But the combination does not explicitly disclose [[ predetermined characteristic comprises ]] a shared color family.
However, Van teaches wherein the predetermined characteristic comprises a shared color family (Van, Page 8, Line 1-25, “there wlll be 36 color families in total, each consisting of 200 colors. Each color family will preferably have a range of 10° on the color circle… a parameter will be assigned to each family… The combination allows a simple navigation on the color chart).
Van and Rodrigues are analogous since both of them are dealing with presenting multiple color/appearance options to a user to aid in selecting the best match. Rodrigues provided a way of generating and displaying multiple candidate coating images for the purpose of selecting a refinish formula that matches a target coating on a vehicle. Van provided a way of grouping multiple related colors into structured color families each with identifying parameter and let user navigate to virtually similar colors within the same family. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate the color family grouping taught by Van into the invention of Rodrigues such that the predetermined characteristic used to select renders belong to the same color family and making it easier and a faster for the user to evaluate only visually related candidate colors.
Claim(s) 28 is/are rejected under 35 U.S.C. 103 as being unpatentable over Rodrigues et al. (US 20080291449 A1, hereinafter Rodrigues), in view of (Colbert et al , BRDF,Shop Creating Physically Correct Bidirectional Reflectance Distribution Functions , 200602 , IEEE, hereinafter Colbert) as applied to Claim 21 above and further in view of Tronci (“Intro to ParaView”, 20200411).
Regarding Claim 28. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination does not explicitly disclose but Peng teaches wherein the material attribute comprises a travel variable (Peng, Paragraph [0001], “cosmetic compositions … having color travel effects” [0002], “interference pigments with unique, spectacular effects, such as color travel ("color variable")” [0014], “Pigments having color travel effects are defined as exhibiting angle-dependent color change between a number of intense interference colors”).
Peng and Rodrigues are analogous since both of them are dealing with reproducing and evaluating special-effect coatings whose appearance depends on viewing and illumination geometry. Rodrigues provided a way of displaying and comparing appearance-matching images for vehicle coatings at multiple viewing angles. Peng provided a way of defining and controlling a "color travel" prope11y as a distinct appearance attribute of the coating material. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate the "color travel" attribute taught by Peng into the appearance characteristics framework of Rodrigues such that travel is treated as an adjustable material attribute in the comparison process. The motivation is to allow users to evaluate and select coatings that better match angle-dependent color shift, which Rodrigues already considers by showing candidate images at multiple aspecular angles.
Claim(s) 31-33, 39 is/are rejected under 35 U.S.C. 103 as being unpatentable over Rodrigues et al. (US 20080291449 A1, hereinafter Rodrigues), in view of (Colbert et al , BRDF,Shop Creating Physically Correct Bidirectional Reflectance Distribution Functions , 200602 , IEEE, hereinafter Colbert) as applied to Claim 21 above and further in view of Peng et al. (US 20150190316 A1, hereinafter Peng).
Regarding Claim 31. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
combination does not explicitly disclose but Tronci teaches configure the computer system to rotate or animate at least one physical based render selected from the plurality of rendered physical based renders (Tronci, Page 2, “Rotate your point of view by holding the left button and panning around with the mouse” Page 5, “On the top of the window you can see some play/stop/rewind style of controls. These allow you to cycle through all the case files…araView will still cycle through them, treating them as frames of an animation”).
Tronci and Rodrigues are analogous since both of them are dealing with on-screen rendered visualizations that a user inspects to make a decision about the displayed content. Rodrigues provided a way of presenting candidate images for visual comparison of coating appearance. Tronci provided a way of interactively rotating and animating a rendered view of data to aid inspection. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate rotation and animation controls from Tronci into Rodrigues so that at least one of the displayed coating renders can be rotated or animated during evaluation. The motivation is to let the user examine appearance under different orientations and over time to better judge visual match, which is consistent with Rodrigues’ stated purpose of comparing appearance.
Regarding Claim 32. the combination of Rodrigues and Cobert and Tronci teaches the invention in Claim 31.
The combination further teaches configure the computer system to rotate a first portion of physical based renders selected from the plurality of rendered physical based renders (Tronci, Page 8, “You can … splitting the render view with the buttons on the top left of the render view to see datasets side by side, or by crating many more Layouts” “Click the Split Horizontal or Split Vertical button on the top left of the RenderView) while a second portion of physical based renders selected from the plurality of rendered physical based renders remain static (Tronci, Page 9-10, “Then, click the Render View button. Right click anywhere on the view you just opened and select Link Camera…” “Now just click on the other 3D view (the one on the left in the current example). This will link the cameras of the two views” “Now you can click on any other view. The Pipeline Browser will update to the data being displayed in the selected view. So, you can have two linked views showing different things. For example, below we look at the raw pressure wave 1 and its Isosurfaces”).
Tronci and Rodrigues are analogous since both of them are dealing with simultaneous, side-by-side visual comparison of rendered views to support decision-making. Rodrigues provided a way of arranging target and candidate images adjacent to each other to select the best match. Tronci provided a way of selectively synchronizing viewpoint changes across only some of the displayed views via camera linking. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate selective camera linking from Tronci into Rodrigues so that a first portion of the displayed coating renders can be rotated in sync while a second portion remains static as a reference. The motivation is to improve visual comparison by letting the user spin a group of candidates together while keeping an unmodified baseline for reference, which aligns with Rodrigues' purpose of choosing the closest match in color and appearance.
Regarding Claim 33. the combination of Rodrigues and Cobert and Tronci teaches the invention for physical based renders in Claim 31.
The combination further teaches configure the computer system to rotate all physical based renders selected from the plurality of rendered physical based renders simultaneously (Tronci, Page 8-10,“Click the Split Horizontal or Split Vertical button on the top left of the RenderView” “Right click anywhere on the view you just opened and select Link Camera….” “Now just click on the other 3D view…This will link the cameras of the two views”; it is noted by applying the same Link camera across all currently split views, you end up with all displayed view having linked cameras, at that point, when you rotate one, they all rotate together simultaneously).
Tronci and Rodrigues are analogous since both of them are dealing with multiple visual renderings being displayed at once for side-by-side evaluation. Rodrigues provided a way of creating and displaying multiple realistic matching images for selecting a best match. Tronci provided a way of globally synchronizing camera viewpoint across multiple split render views so that all of them update together. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate global camera linking from Tronci into Rodrigues such that all of the simultaneously displayed coating renders rotate together at once. The motivation is to allow uniform orientation and motion across all candidate views, which improves direct, apples-to-apples visual comparison for final selection of the best match in appearance.
Regarding Claim 39, it recites limitations similar in scope to the limitations of Claim 31 and therefore is rejected under the same rationale.
Claim(s) 35 is/are rejected under 35 U.S.C. 103 as being unpatentable over Rodrigues et al. (US 20080291449 A1, hereinafter Rodrigues), in view of (Colbert et al , BRDF,Shop Creating Physically Correct Bidirectional Reflectance Distribution Functions , 200602 , IEEE, hereinafter Colbert) as applied to Claim 21 above and further in view of Lee (US 20120046987 A1).
Regarding Claim 35. the combination of Rodrigues and Cobert teaches the invention in Claim 21.
The combination does not explicitly disclose but Tronci configure the computer system to communicate a particular physical based render within the plurality of rendered physical based renders to a formulation device the formulation device configured to generate a material comprising the particular material (Lee, Abstract, “The paint mixer is used to mix selected paint components according to a specified paint formula” Paragraph [0031], “mixing a sample of paint according to the recommended paint formula outputted by the paint matching system” [0033], “using a paint mixer, mixing a quantity of the paint according to the formula”).
Lee and Rodrigues are analogous since both of them are dealing with matching an existing coating's color/appearance and producing or obtaining material to repair that coating. Rodrigues provided a way of selecting a refinish formula by visually comparing generated candidate images to the target coating. Lee provided a way of automatically driving a paint mixer with the recommended formula to physically mix and deliver the coating. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention was made to incorporate automated formula-to-mixer communication from Lee into Rodrigues such that, after visually selecting the best match in Rodrigues, that selected formula is transmitted to a formulation/mixing device to actually generate the coating material. The motivation is to streamline repair by going directly from visual match selection to on-demand physical production of the matched paint, which both references identify as desirable (fast, accurate match for repair work).
Response to Arguments
The rejection of Claim 40 under 35 U.S.C. 101 is withdrawn in view of Applicant’s amendment to the independent Claim 40.
Applicant’s arguments with respect to claim 21, 36, 40, filed on 1/26/2026, with respect to rejection under 35 USC § 103 have been considered but are not persuasive for the reasons set forth below.
Applicant asserts that Rodrigues does not disclose generating displayed representations using a physically based rendering engine driven by BRDFs or BTFs, and that Rodrigues merely compares precomputed colorimetric image results (L*a*b*, XYZ - RGB) rather than dynamically re-rendering a plurality of materials in response to a single user adjustment. Applicant's argument is not persuasive because it attacks Rodrigues in isolation. The rejection does not rely on Rodrigues to teach the physically based rendering engine or BRDF/BTF limitations. Rather, as set forth in the rejection, Rodrigues is relied upon solely for the following limitations: (1) a computer system for
dynamically displaying multiple physical based renders comprising one or more processors; (2) one or more computer-readable media having stored thereon executable instructions; (3) display, concurrently, a plurality of rendered physical based renders, each depicting a digital representation of a particular material with a coating applied thereon; and (4) each physical based render being selected based upon a predetermined characteristic shared by each render (e.g., OEM paint code, model year, manufacturing site information). It is well-established that one cannot show non obviousness by attacking references individually when the rejection is based on a combination. See In re Merck & Co., 800 F.2d 1091, 1097 (Fed. Cir. 1986). The physically based rendering engine and BRDF /BTF limitations are supplied by Colbert, not Rodrigues, as expressly stated in the rejection.
Applicant further asserts that Colbert operates only in a single-material authoring context and does not disclose: (a) selecting a plurality of different materials as a comparison set each associated with its own reflectance data; (b) concurrently displaying multiple distinct materials for comparison; or (c) receiving a single user command and applying it to synchronously re-render a plurality of different materials while maintaining each as a distinct candidate. This argument is not persuasive for the following reasons. First, with respect to Colbert's disclosure, Applicant mischaracterizes the scope of Colbert's teaching by focusing narrowly on the single-canvas use case while ignoring Colbert's broader description of its rendering architecture. Colbert expressly discloses a real-time rendering interface that evaluates the BRDF model across rendered geometry: "In rendering the lobes on the arbitrary mesh, we carry out
integration of the environment at every visible pixel of the mesh" ( Colbert, Page 33). The claim does not require that the plurality of renders be authored simultaneously or that the BRDF parameter adjustment system be originally designed in a multi-material context. The claim requires only that (i) a plurality of renders is displayed, (ii) UI elements are configured to adjust a material attribute associated with the plurality, and (iii) a received command adjusts that specific material attribute on each render within the plurality. Nothing in the claim language requires a single command to trigger
a simultaneous re-render of all candidates in a single atomic operation - Applicant is reading limitations into the claim that are not there. Second, with respect to the obviousness combination, the proper inquiry under 35 U.S.C. § 103 is not
whether either reference individually discloses the complete claimed invention, but whether a person of ordinary skill in the art would have been motivated to combine the teachings of the references with a reasonable expectation of success. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007). Rodrigues discloses a system that concurrently displays a plurality of candidate coating material renders selected by a shared characteristic (e.g., model year, OEM paint code), with the express goal of allowing a user to compare and select the best appearance match (Rodrigues, Paragraphs-).
Colbert discloses an interactive BRDF-based rendering system in which a user manipulates material attributes - roughness, anisotropy direction, and albedo - through a set of UI brush tools and immediately visualizes the result on a rendered object (Colbert, Pages 30- 33). A person of ordinary skill in the art would have recognized that incorporating Colbert's interactive material-attribute adjustment interface into Rodrigues' multi-image comparison workflow would have been a straightforward and predictable combination of known techniques. The motivation is clear: Rodrigues itself identifies the goal of its system as enabling a user to judge and select the best color and appearance match among multiple displayed candidates. The ability to dynamically adjust material rendering parameters - as Colbert teaches - directly improves a user's ability to make that judgment by allowing real-time exploration of how each candidate material appears under different rendering conditions. This is precisely the type of "obvious to try" combination with a finite number of identified, predictable solutions that KSR recognizes as sufficient for a finding of obviousness. KSR, 550 U.S. at 421.
Applicant further asserts that Rodrigues and Colbert solve different problems in different contexts and that their combination does not naturally or predictably yield the claimed synchronized, multi-material physically based rendering system. This argument is not persuasive. The fact that two references address different aspects of a problem does not preclude their combination - indeed, this is precisely the scenario that§ 103 combinations are designed to address. See In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006). Both Rodrigues and Colbert operate in the domain of computer-based material
appearance visualization: Rodrigues in the context of automotive coating color matching and Colbert in the context of physically based material design. Both references are thus in the same field of endeavor - computer graphics and material appearance rendering - and a person of ordinary skill in the art would have been familiar with both. The combination does not require any unpredictable result: applying Colbert's well-known BRDF-based rendering and interactive brush-based UI into Rodrigues' established multi-image display framework would have yielded the claimed system through routine engineering judgment with a reasonable expectation of success. Hence the combination of prior arts Rodrigues and Colbert fully anticipates all the limitations currently claimed. Hence applicant remarks cannot be considered persuasive.
In regard to Claims 22-35, 37-39, they directly/indirectly depends on independent Claim 21, 36, 40 respectively. Applicant does not argue anything other than the independent claim 21, 36, 40. The limitations in those claims in conjunction with combination previously established as explained.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
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/YuJang Tswei/Primary Examiner, Art Unit 2614