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`06816/043001
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`THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Dariush Divsalar and Fabrizio Pollara
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`Serial No:
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`08/857,021
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`GROUP ART UNIT:
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`2786
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`all“
`V355
`7/13m
`MW
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`EXAMINER:
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`3. Baker
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`RECENED
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`FEB 2 3 1999
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`Group 270°
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`Filed:
`For:
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`05/15/97
`HYBRID CON-
`CATENATED CODES
`AND ITERATIVE DE-
`CODING
`
`
`AMENDMENT
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`Honorable Assistant Commissioner of
`3’51‘1
`Patents and Trademarks
`567 Washington, DC. 20231
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`VT
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`7"
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`Dear Sir:
`
`In response to the Office Action dated 10/05/98 in connection with the above-identified application,
`please enter and consider the remarks set forth below.
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`Date ofDepositL
`I hereby certify under 37 CFR 118(3) that this correspondence is being
`deposited with the United States Postal Service as first class mail with
`sufficient postage on the date indicated above and is addressed to the
`Commissioner of Patents and Trademarks, Washington, D C. 20231.
`dim/g1 dim:
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`
`
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`ERICSSON EXHIBIT 1020
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`

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`068 1 6/043 001
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`IN THE CLAIMS
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`13.
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`(Amended) A system for error-correction coding of a source of original digital data
`elements, comprising:
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`(a)
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`at least one interleaver, each coupled to the source of original digital data elements,
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`for modifying the order of the original digital data elements to generate respective
`interleaved elements; and
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`éz/
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`(b)
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`a si_ng1§ systematic recursive convolutional encoder mm, coupled to the source
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`of original digital data elements and to interleaved elements from at least one
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`interleaver, for generating a set of coded output elements derived from the original
`digital data elements;
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`wherein the system for error-correction coding outputs the set of coded output elements and
`the original digital data elements.
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`

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`06816/043001
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`REMARKS
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`Claims 1-74 were in issue. The Examiner indicated that claims 56, 57, and 59 contain allowable
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`subject matter. By this amendment, claim 13 has been amended, no claims have been canceled, and
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`no claims have been added. Accordingly, claims 1-74 are presented and claims 1-55, 58, and 60-74
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`are at issue. By this amendment, all claims are believed to be in condition for allowance.
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`Priority Date
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`Applicants note that the present application, filed 5/ 15/97, claims priority to provisional patent
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`application serial no. 60/017,784, filed 5/15/96. See cover letter to PTO dated 5/15/97 accompanying
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`the filing of the present application and claiming priority to the provisional application pursuant to
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`35 USC §119(e)(l), and the Response to Notice to File Missing Parts of Application and Request
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`to Correct Filing Receipt filed 11/20/97, requesting correction of the filing receipt to pr0perly note
`the priority claim.
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`Consequently, the critical date with respect to the present application is 5/15/95. References
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`published after that date cannot be asserted as prior art under fil102(b). Further, patent applications
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`filed after the priority date cannot be asserted as prior art under 7102(e).
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`The §102 Rejection based on Le Goff
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`The Examiner has rejected claims 13-17, 23, 24, 60, and 61 under 35 USC. §102(b) as being
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`anticipated by the reference to Le Goff, having an apparent publication date of 5/94. Applicant
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`respectfully traverses this rejection with respect to the claims as presented.
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`With respect to claims 13-17, Applicants have amended claim 13 to clarify that it recites a si_ngl_e
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`systematic recursive convolutional encoder 312qu (one embodiment coming within claim 13 is
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`shown in FIG. 6B of the application). In contrast, Le Goff teaches use of two encoders (C1 and C2
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`in Figure 1). Hence, Applicants’ invention provides an advantage as being simpler to implement.
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`Le Goff neither teaches nor suggests that only a single encoder can be used. Hence, Le Goff does not
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`anticipate nor make obvious the invention as presently claimed in claims 13-17.
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`

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`06816/043001
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`With respect to claims 23-24 and 60-61, Le Goffteaches that the output of the turbo encoder shown
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`in Figure 3 must be interleaved before being applied to a signal mapping function. See, for example,
`Le Goff p. 646, first column:
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`“In order to obtain symbols affected with uncorrelated noises at the turbo-decoder
`input, an interleaver I2 has to be inserted between the puncturing function and the
`modulator.” [Emphasis added]
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`Thus, the modulator in Le Goff is coupled to an intermediate interleaver, and not to the turbo
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`encoder outputs. In contrast, as set forth in claims 23-24 (and in corresponding language in their
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`method counterparts, claims 60-61), the multilevel modulator is coupled to the original digital data
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`elements and to the coded output elements of each systematic convolutional encoder without an
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`intermediate interleaver. Again, Applicants’ invention provides an advantage as being simpler to
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`implement. Le Goff neither teaches nor suggests that an intermediate interleaver can be omitted;
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`indeed, Le Gofl' explicitly teaches away from omission of such an interleaver. Hence, Le Goff does
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`not anticipate nor make obvious the invention as presently claimed in claims 23-24 and 60-61.
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`The Remaining §102 Rejections
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`The Examiner has also rejected a number of other claims based on the references set forth in the
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`following Table I. HoWever, in light of Applicants’ priority date of 5/15/96, none of these references
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`are properly applicable as prior art under §§102(b) or 102(e). Consequently, Applicants submit that
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`the claims rejected based on these references are allowable.
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`TABLE I
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`Reference
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`Applied to Claims
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`Apparent Publication
`or Filing Date
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`
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`
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`11/95 publication
`1-17, 23-54, and 60-74 under 102(b)
`Divsalar et al.‘
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`
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`18-22 under 102(b)
`11/95 publication
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`
` Hladik '962
`6, 7, 9,11-14,16-19, 21, 22, 43, 44,
`7/17/96 filing
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`
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`46, 48, and 49 under §102(e)
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`
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`
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` 11/95 publication
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` 9/95 publication
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`Thitimajshima
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`55 under §103(a)
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`Siala (with Thitimaj shima)
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`58 under §103(a)
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`l
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`Applicants note that this reference is their own work.
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`-4-
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`06816/043001
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`Accordingly, Applicant submits that none of the references, alone or in combination, anticipate or
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`make obvious the invention as presently claimed. Applicant submits that this case is now in
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`condition for allowance. Therefore, Applicant respectfully requests reconsideration and reexami-
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`nation of the present application and allowance of the case at an early date.
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`Please apply any credits or charge any deficiencies to our Deposit Account No. 06-1050.
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`Respectfully submitted,
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`.
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`FISH & RICHARDSON
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`Dated: February4, 1999 W
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`
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`By:
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`John Land, #29,554
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`4225 Executive Square
`Suite 1400
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`La Jolla, CA 92037
`(619) 678-5070
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`