IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Control No.: 90/012,590
`Patent No.: 6,243,099
`Confirmation No.: 2143
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`Examiner: KE, PEN G
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`Atty Docket No. GRND-L6
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`RESPONSE TO OFFICE ACTION
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`Hon. Commissioner for Patents, Alexandria VA 22313-14 50
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`Sir or Madam:
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`Patent Owner responds as follows to the outstanding Office Action. This is
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`necessarily a long response, so for the Examiner's convenience Patent Owner provides a
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`Table of Contents as follows. Other papers flied as part of this response include:
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`• A Rule 132 expert Declaration of Dr. James Oliver, including visual exhibits;
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`• A Rule 132 Declaration of Ford Oxaal;
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`• An Information Disclosure Statement and cited documents, with transmittal
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`letter.
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`90/012,590
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`Response to First Office Action
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`p.1
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`

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`TABLE OF CONTENTS
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`TABLE OF CONTENTS .......................................................................................................................... 2
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`REMARKS ................................................................................................................................................. 4
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`Overview of Selected Arguments ............................................................................................................. 5
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`"Image Processing" is the Field of the Inventions ............................................................................. 7
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`Image Processing Is Distinct From Computer Graphics ............................................................................. 7
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`Level of Ordinary Skill .................................................................................................................................. 8
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`Critical Date ....................................................................................................................................................... 8
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`General Notes On the Oxaal Patents .................................................................................................... 10
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`Source Code Example ................................................................................................................................................. 11
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`What Luken Does and Does Not Disclose ........................................................................................... 13
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`What Gullichsen Does and Does Not Disclose .................................................................................. 15
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`What Greene Does and Does Not Disclose ......................................................................................... 16
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`What Haeberli Does and Does Not Disclose ...................................................................................... 18
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`Contrary to Accepted Wisdom ............................................................................................................... 19
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`Commercial Success ................................................................................................................................... 20
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`General Notes On Claim Interpretation .............................................................................................. 20
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`Interpretation of "full-surround" ......................................................................................................................... 20
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`Interpretation of "p-surface" .................................................................................................................................. 21
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`Interpretation of "p-sphere" ................................................................................................................................... 22
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`Interpretation of "texture mapping" .................................................................................................................. 22
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`Interpretation of "selecting a perspective of view" .................................................................................... 22
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`Interpretation of "triangulation" .......................................................................................................................... 22
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`Interpretation of "first texture p-surface data set" ..................................................................................... 22
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`Interpretation of "projection" ................................................................................................................................ 23
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`Interpretation of "textured p-surface" .............................................................................................................. 23
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`Claim 11 ........................................................................................................................................................... 24
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`Text of Claim 11 ............................................................................................................................................................. 24
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`Claim 11 over Luken in view of Greene (Issue Set (1)) ............................................................................ 24
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`Insufficient Rationale To Combine ................................................................................................................................... 24
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`Combination Does Not Reach Claims .............................................................................................................................. 25
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`p.2
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`No " ... texture mapping ... onto said p-surface ... substantially equivalent to projecting ... " ......... 25
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`Other Claim Limitations Not Met ............................................................................................................................... 26
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`Greene Teaches Away .............................................................................................................................................................. 26
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`Luken Teaches Away ................................................................................................................................................................ 27
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`Combination Would Render Luken Inoperable ........................................................................................................ 27
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`Contrary To Common Wisdom ........................................................................................................................................... 27
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`Non-analogous Art .................................................................................................................................................................... 27
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`Asserted Rationale Would Not Enable Claimed Combination ........................................................................... 28
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`Claim 11 over Luken in view of Haeberli (Issue Set (2)) ......................................................................... 29
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`Insufficient Rationale To Combine ................................................................................................................................... 29
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`Luken Teaches Away ................................................................................................................................................................ 30
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`Combination Would Render Luken Inoperable ........................................................................................................ 30
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`Combination Does Not Reach Claims .............................................................................................................................. 31
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`No " ... texture mapping ... onto said p-surface ... substantially equivalent to projecting ... " ......... 31
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`Other Claim Limitations Not Met ............................................................................................................................... 31
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`Contrary To Common Wisdom ........................................................................................................................................... 32
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`Non-analogous Art .................................................................................................................................................................... 33
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`Asserted Rationale Would Not Enable Claimed Combination ........................................................................... 33
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`Claim 11 over Gullichsen in view of Greene (Issue Set (3)) ................................................................... 35
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`Insufficient Rationale To Combine ................................................................................................................................... 3 5
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`Greene Teaches Away .............................................................................................................................................................. 37
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`Combination Does Not Reach Claims .............................................................................................................................. 37
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`No " ... texture mapping ... onto said p-surface ... substantially equivalent to projecting ... " ......... 37
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`Other Claim Limitations Not Met ............................................................................................................................... 39
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`Contrary To Common Wisdom ........................................................................................................................................... 40
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`Non-analogous Art .................................................................................................................................................................... 40
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`Asserted Rationale Would Not Enable Claimed Combination ........................................................................... 40
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`Claim 11 over Gullichsen in view of Haeberli (Issue Set ( 4)) ............................................................... 41
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`Insufficient Rationale To Combine ................................................................................................................................... 41
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`Combination Does Not Reach Claims .............................................................................................................................. 43
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`No " ... texture mapping ... onto said p-surface ... substantially equivalent to projecting ... " ......... 44
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`Other Claim Limitations Not Met ............................................................................................................................... 45
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`Contrary To Common Wisdom ........................................................................................................................................... 46
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`Non-analogous Art .................................................................................................................................................................... 46
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`Asserted Rationale Would Not Enable Claimed Combination ........................................................................... 46
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`CONCLUSION ........................................................................................................................................ 47
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`p.3
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`

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`REMARKS
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`Examiner Ke is thanked for his hard work on this case.
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`Of the issued Claims (1-22), Claim 11 is being reexamined in this proceeding. Claim
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`11 has been rejected over Luken 5,923,334 or Gullichsen 5,796,426, in view of Greene1 or
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`Haeberli.2
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`The art rejections are all respectfully traversed.
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`1 Greene, "Application of World Projections," Proceedings of Graphics Interface '86, pp. 108-
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`114, May 1986.
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`2 The citation given is "Texture Mapping as a Fundamental Drawing Primitive," Proc. Fourth
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`Eurographics Workshop on Rendering, pp.259-266, June 1993. However, the Haeberli article discussed
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`does not have the same pagination.
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`90/012,590
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`Response to First Office Action
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`p.4
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`

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`Overview of Selected Arguments
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`This reexamination can be decided very simply: ALL claims have some limitation
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`relating to use of a textured p-surface? None of the references show anything like this.
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`None of the asserted combinations of references would have suggested anything like this
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`to a person of ordinary skill. Thus the asserted combination does not meet the claims.
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`The various reference combinations are discussed in detail below. Some of the
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`notable points in that analysis include:
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`•
`
`•
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`Every rejection relies on non-analogous art (from computer graphics). "Image
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`Processing'' and "Computer Graphics" were different fields on the last effective filing
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`date. (Even today those fields are regarded as different, and they were more distinct in
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`the past.) All of the principal references are from the Image Processing art. Thus in
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`order to pull in a secondary reference from computer graphics, a rejection must show
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`that it is an area to which one of ordinary skill would naturally turn. This has not been
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`shown.
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`Every single rejection relies on the stated motivation of: "in order to create a
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`projection of the complete environment." This rationale: is not meaningful to one of
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`ordinary skill; would not lead to the claim limitations being met; would not
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`differentiate between lead reference and combined references; and would not provide
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`enough guidance to enable creation of the claimed combinations.
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`• The claimed combinations are contrary to accepted wisdom, in that additional steps
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`are added to the image processing pipeline.
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`• The references relied on are no better than categories (1) and (2) of known approaches,
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`3 Claim 11: "0 0
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`0 texture mapping full-surround image data onto said p-surface such that the
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`resultant texture map is substantially equivalent to projecting full-surround image data onto the p-surface
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`from said view point to thereby generate a texture mapped p-sphereo 0 0,
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`90/012,590
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`Response to First Office Action
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`p.S
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`which are criticized from col.1 1.54 - col.2 1.26 of the issued patent.
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`The following response also includes a detailed review of the disclosure supporting the
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`textured p-surface. Expert testimony with extensive further analysis is included in the Rule
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`132 Declaration of Dr. Oliver filed herewith.
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`Thus a prima facie case of obviousness has not been made. In addition, Patent Owner
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`also submits evidence of commercial success, and its nexus to claim limitations, herewith.
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`Even if a prima facie case of obviousness had been made out, such secondary
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`considerations are always relevant.
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`90/012,590
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`Response to First Office Action
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`p.6
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`

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`"Image Processing" is the Field of the Inventions
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`The relevant field of art is Image Processing. This is the segment of information
`
`processing which deals with handling two-dimensional representations of the external
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`world. For example, the image formed by a lens is two-dimensional ("2D"), and correcting
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`the perspective of such an image (or part of such an image) would be a 2D-to-2D
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`transform.
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`Image Processing Is Distinct From Computer Graphics
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`As detailed in the expert Declaration of Dr. Oliver, the relevant art is unage
`
`processing. This is important to notice, because the fields of image processing and
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`computer graphics have become far less distinct since the Oxaal filing. At the time of the
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`Oxaal filing, it was not only surprising to perform the claimed functions, but also
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`surprising to turn to the art of computer graphics to exploit hardware capabilities which
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`were not otherwise necessary.
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`At the time of the Oxaal filing, image processing was often directed to analytic
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`techniques, or to manipulation of images which (by the standards of the time) consumed
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`large amounts of memory; by contrast, computer graphics were originally driven by
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`synthesis (e.g. constructing virtual objects for computer-aided design, simulations or video
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`games).
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`In contrast, the field of computer graphics deals with the reverse process, namely,
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`the synthesis of digital images from 2D or 3D models. These fields developed in parallel
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`through the past 40 years, generally with distinct research communities. For example, a
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`top journal for practitioners of image processing is IEEE Transactions on Pattern Ana!Jsis and
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`Machine Intelligence (P AMI), while the computer graphics community was drawn to the
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`Association for Computing Machinery's (ACM) SIGGRAPH Conference and published
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`90/012,590
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`Response to First Office Action
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`p.7
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`in journals like the ACM's Transactions on Graphics.
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`The volumes of data which had to be managed in image processing were very large
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`in relation to the computing hardware of the 1980s, and still very challenging with the
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`computing hardware of the late 1990s. Often high-end workstations were used for such
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`tasks, in part because of bus limitations and processor throughput. It was often difficult to
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`achieve good performance in interactive image processing applications because of this.
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`Thus adding steps to the processing pipeline in an interactive image processing
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`architecture would have been generally regarded as a very bad idea.
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`The fields of image processing and computer graphics remained generally distinct
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`through the mid-1990's and only started to "cross-fertilize" in the late 1990's as digital
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`technologies began to revolutionize traditional photography.
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`The concept of "texture mapping'' was developed in computer graphics to apply
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`"skins" to virtual objects. This was a way of adding realism to a very simplified synthetic
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`structure. Since there was no comparable deficiency of realism in image processing, there
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`was no perceived need, prior to the Oxaal filing, to add such techniques in the art of image
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`processmg.
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`Level of Ordinary Skill
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`The level of ordinary skill in the relevant art can be assumed to be (for example) a
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`BSEE or BS in Computer Science, with 1 to 5 years of experience in image processing.
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`Critical Date
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`The present application has
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`two effective priority dates. For conservative
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`arguments, the present argument assumes that the later date of January 12, 1998, is
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`applicable. However, some relevant teachings are also found in the application which
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`issued as the '782 patent. Patent Owner does not waive any claim to priority, but merely
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`90/012,590
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`Response to First Office Action
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`p.8
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`

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`points out that, even with the later priority date, all claims should be confirmed as
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`patentable.
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`90/012,590
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`Response to First Office Action
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`p.9
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`

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`General Notes On the Oxaal Patents
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`Image Processing generally provides 2D-to-2D transformations. Image data was
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`bulky, by the standards of the 1990s, and great emphasis was placed on efficiency use of
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`processor cycles and memory bandwidth. However, the '099 and '035 patents suggested,
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`among other teachings, that an additional processing stage should be ADDED into the
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`processing pipeline. Where bandwidth and throughput are important constraints, this
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`would normally be an automatically disfavored change (in any computing context).
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`A 2D image from a lens already represents the result of a 3D-to-2D transformation
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`(performed by the optical train). Transforming that 2D image back into three dimensions,
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`to form a texture-mapped p-surface (in the language of the Oxaal patents), seems like a
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`surprising step backwards.
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`However, that (among other things) is what the Oxaal patent teaches. A 2D data
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`set (such as an environment map) is mapped onto a three-dimensional p-sphere using
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`texture mapping. The textured p-sphere is then used to generate the actual view( s) seen by
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`an interactive viewer(s). Mr. Oxaal realized, in 1997 or before, that the increasing
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`availability of cheap graphics processing hardware would make this additional step
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`practical, and advantageous.
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`Previous image processing techniques had provided many clever techniques for
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`transforming a 2D source image (such as a color image from a CCD onto which a lens
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`projected an image) into a 2D viewable image (such as might be displayed on a computer
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`monitor). In the particular context of viewing parts of a very large available field of view,
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`the various primary references provide data handling and approximations to speed up the
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`process of obtaining a view from a larger image data set. However, none of the references
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`relied on show anything like the creation of a "texture-mapped p-surface" as an
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`90/012,590
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`Response to First Office Action
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`p.10
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`

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`intermediate stage between the 2D environment map and the 2D view window.
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`Source Code Example
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`One example of implementation appears in Figs. 9A-10B of the '099 patent (which
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`are now being explicitly included in the '035 patent too).
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`The function readTexture, which is listed from the middle of 9B through the end
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`of 9C, opens two flies (char* flle1 and char* flle2) and returns a Texture t containing two
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`arrays of pixel values, tex1 and tex2 (essentially, textures), read in from flle1 and flle2.
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`The function display, listed from the middle of 9D through the middle of 9F, calls
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`createHemisphere (defined on 9B as HEMISPHERE) twice, passing it first tex1 and then
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`tex2 to be texture mapped onto corresponding hemispheres. See also, col. 7, lines 21-34,
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`discussing texture mapping of tex1 and tex2 to the triangulated sphere.
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`Figures 10A and 10B list createHemisphere, which creates the texture mapped
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`hemispheres. The function createHemisphere takes a display list number and the number
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`of points to a side (which determines, for example, the size and number of triangles), and
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`returns a texture mapped hemisphere to be displayed.
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`Looping for each of the numPts points, OpenGL is notified that a triangle strip will
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`be drawn (geom is GL_TRIANGLE_STRIP in this embodiment, see initialize_objects,
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`Fig. 9D). The map function is passed reference coordinates (u, v) on a unit square that
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`index the hemisphere to be texture mapped. The map function computes and returns a
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`point on the sphere (x, y, z) corresponding to (u, v), and then texture coordinates tx and tz
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`are calculated. Tx and tz correspond to a point in the image (source) texture. The function
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`p.11
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`glTexCoord2f(tx,tz), followed by g1Vertex3f(x,y,z) deflnes a hemisphere vertex and its
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`corresponding texture coordinate as part of the triangle strip hemisphere geometry. The
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`map function, vertex creation and texture coordinate calculations are then repeated for the
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`other two vertices of the triangle.
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`Once all points to be mapped to the hemisphere have been mapped, the loop
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`terminates, and the texture mapped hemisphere (in this embodiment, a list of texture
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`mapped triangular strips) is returned.
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`90/012,590
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`Response to First Office Action
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`p.12
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`

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`What Luken Does and Does Not Disclose4
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`Luken presents a data structure for handling environment maps. The main teaching
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`of Luken is shown in its Figure 5, which illustrates these triangular data structures.
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`Handling the large volumes of data in environment maps was an important concern in
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`1996, and this appears to be Luken's main thrust. Figure 4 merely shows the implied
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`relation between the eight 2-D data structures of Figure 5. The octahedron of Figure 4 is
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`merely hypothetical.
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`Luken does not create any intermediate texture or object between the original
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`image data and the resulting view. Even more clearly, Luken does not use texture mapping
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`to create any intermediate texture or object between the original image data and the
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`resulting view.
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`Luken does not disclose texture mapping, instead explicitly evaluating view window
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`pixels, and optimizes memory access using a disclosed data structure that would be
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`incompatible with texture mapping. Luken teaches advantages in its disclosed memory
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`structure that amount to advantages for not texture mapping, i.e., teaching away from
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`texture mapping. Luken, col. 5, lines 42-64. In fact, Luken states that the improved
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`performance resulting from its environment map is due to "the use of a triangular data
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`structure in defining the environment map", the same data structure that is incompatible
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`with texture mapping. Luken, col. 3, lines 47-55. The MPEP states5
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`:
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`'"'The test for obviousness is not whether the features of a secondary reference
`may be bodily incorporated into the structure of the primary reference .... Rather,
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`4 The attached Rule 132 Declaration of Prof. Oliver provides an extensive analysis of the
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`references of record from a well-qualified expert. This is fact evidence which verifies and supports the
`
`explanations above.
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`5 MPEP 2145(III).
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`90/012,590
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`Response to First Office Action
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`p.13
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`

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`the test is what the combined teachings of those references would have suggested
`to those of ordinary skill in the art." In re Keller, 642 F.2d 413, 425, 208 USPQ 871,
`881 (CCPA 1981)."
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`90/012,590
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`Response to First Office Action
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`p.14
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`

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`What Gullichsen Does and Does Not Disclose6
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`Gullichsen uses a method of approximation to speed up the process of obtaining a
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`viewable
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`image from an environment map. Gullichsen does not create any
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`intermediate texture or object between the original image data and the resulting
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`view. Gullichsen refers to texture mapping, but does not use texture mapping to create
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`any intermediate object/ much less any p-surface or p-sphere (as those terms are deflned
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`in the Oxaal patents).
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`There is no reason why one of ordinary skill would have modified Gullichsen to
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`add a texture-mapped intermediate object into the processing pipeline for image viewing.
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`Gullichsen col. 9, lines 20-32 and 41-45, describes how "a flsheye or other wide
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`angle image of a synthetic three dimensional environment can be produced" (emphasis
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`added), i.e. how to map from a three dimensional environment to a wide angle image or
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`other surface that has the same shape as the display. At best, this is the opposite of
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`"texture mapping ... onto [a] p-surface ... ".
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`Gullichsen col. 5, lines 8-30, describes hardware suitable for "texture warping'', i.e.,
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`changing the shapes of source textures. "Texture warping" is not the same as texture
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`mappmg.
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`The subsequent section of Gullichsen, col. 5, line 30 to col. 6, line 30, is part of a
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`discussion of mapping directly from a warped source image directly to a view plane. This
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`6 The attached Rule 132 Declaration of Prof. Oliver provides an extensive analysis of the
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`references of record from a well-qualified expert. This is fact evidence which verifies and supports the
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`explanations above.
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`7 More precisely, Gullichsen refers to texture mapping, but does not use texture mapping to create
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`any intermediate virtual object existing in the virtual world of active computer memory.
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`90/012,590
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`Response to First Office Action
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`p.15
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`

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`1s "the geometric correction necessary to transform the region ... into a perspective
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`corrected field of view." Gullichsen, col. 6, lines 17-19.
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`The portions of Gullichsen cited by the Office Action, and Gullichsen in general,
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`are limited to disclosing mapping from a source image or object directly to a displayable
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`surface (e.g., a view plane); essentially, from 3D to 2D, or 2D to 2D, but never 2D to 3D.
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`Gullichsen does NOT disclose "texture mapping ... onto [a] p-surface ... "as claimed.
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`Gullichsen discloses mapping fisheye images directly to a view plane - without, for
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`example, texture mapping the images to a p-surface. Even if Haeberli disclosed full(cid:173)
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`surround image data (which Patent Owner disputes), adding full-surround image data to
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`direct mapping to a view plane of Gullichsen can not produce "texture mapping full(cid:173)
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`surround image data onto said p-surface such that the resultant texture map is substantially
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`equivalent to projecting full-surround image data onto the p-surface ... "as is recited (with
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`other language) in the context of Claim 11.
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`What Greene Does and Does Not Disclose8
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`Greene (1986) is an ancient reference in the field of computer graphics, concerned
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`primarily with problems like the "chrome-plated lizard" shown in plate 1.9 Greene also
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`briefly addresses using texture mapping in the context of rendering from a world
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`projection to an output image (Greene, p. 112, section 9, second~; see also, p. 111, section
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`9, first ~' and p.112, section 10). "Chrome-plated lizards" and rendering to an output
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`image are unrelated to the fields of or the problems addressed by the '099 and '035
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`8 The attached Rule 132 Declaration of Prof. Oliver provides an extensive analysis of the
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`references of record from a well-qualified expert. This is fact evidence which verifies and supports the
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`explanations above.
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`9 See sections 1-8, "using world projections for surface shading", p. 111, and section 9, first
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`paragraph.
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`90/012,590
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`Response to First Office Action
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`p.16
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`

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`inventions.
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`Greene is not analogous art to the claimed inventions. MPEP §2141.01(a)(1) says:
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`"[A] reference is analogous art to the claimed invention if: (1) the reference is from
`the same field of endeavor as the claimed invention ... ; or (2) the reference is
`reasonably pertinent to the problem faced by the inventor (even if it is not in the
`same field of endeavor as the claimed invention)."
`
`Clearly Greene is not from the same field of endeavor as the claimed inventions (image
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`processing).
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`Greene is also not reasonably pertinent to the problem faced by the inventor of the
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`claimed inventions: there is no reason why, at the beginning of 1998, one of ordinary skill
`
`in the art of image processing would have turned to an ancient computer graphics paper.
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`The Office Action has not defined a "problem faced by the inventor" which would lead
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`one of ordinary skill to turn to a computer graphics art rather than the image processing
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`art.
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`Further, the direct source image to Vlew surface mappmg of Gullichsen 1s
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`incompatible with texture mapping a p-surface step. The MPEP states: 10
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`"If the proposed modification or combination of the prior art would change the
`principle of operation of the prior art invention being modified, then the teachings
`of the references are not sufficient to render the claims prima facie obvious."
`
`The MPEP states:
`
`'"'The test for obviousness is not whether the features of a secondary reference
`may be bodily incorporated into the structure of the primary reference .... Rather,
`the test is what the combined teachings of those references would have suggested
`to those of ordinary skill in the art." In re Keller, 642 F.2d 413, 425, 208 USPQ 871,
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`10 MPEP §§2143.01(VI).
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`90/012,590
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`Response to First Office Action
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`p.17
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`

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`881 (CCPA 1981). " 11
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`What Haeberli Does and Does Not Disclose12
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`Haeberli, like Greene, is an old paper in computer graphics. It appears to be a
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`survey of a very large number of techniques.
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`The Non-Patent Literature document which is visible in PAIR is a very short
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`abstract. It appears that the Office Action is relying on this abstract only. However, for
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`clarity, Patent Owner respectfully notes that the text cited in the Request for Haeberli is
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`not itself the cited publication, as seen by the different page numbering. Patent Owner was
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`unable to find a copy of the actual cited publication. The material provided by Requestor
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`has not itself been shown to be prior art at all. It may well be identical to the actual
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`Haeberli publication, but the Office Action has not shown this, and Patent Owner has no
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`way of knowing whether it is. MPEP §2128 provides that:
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`Absent evidence of the date that the disclosure was publicly posted, if the
`publication itself does not include a publication date (or retrieval date), it cannot
`be relied upon as prior art under 35 U.S.C. 102(a) or (b).
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`Haeberli is not from the same field of endeavor as the claimed invention, nor is it
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`reasonably pertinent to the problem faced by the inventor of the claimed inventions.
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`MPEP 2141.01 (a) (I). Haeberli's most relevant disclosure is its two environment mappings,
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`which are respectively limited to (1) contributions of specular reflections onto a
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`foreground object, or (2) a result that requires recomputation when the direction of view
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`is changed. Haeberli, p. 6.
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`11 MPEP 2145(III).
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`12 The attached Rule 132 Declaration of Prof. Oliver provides an extensive analysis of the
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`references of record from a well-qualified expert. This is fact evidence which verifies and supports the
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`explanations above.
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`90/012,590
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`Response to First Office Action
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`p.18
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`

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`Contrary to Accepted Wisdom
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`The accepted wisdom in image processmg ill 1997 was that computational
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`resources were limited, and (in