`
`PATENT
`Attorney Docket No. 13087.0003-0200
`
`)
`)
`) Group Art Unit: 1742
`)
`) Examiner: Stella Kim YI
`)
`) Confirmation No.: 1088
`)
`)
`)
`)
`
`In re Application of:
`
`Kenneth TYLER
`
`Application No.: 15/267,956
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`Filed: September 16, 2016
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`For: METHOD AND APPARATUS FOR
`CONTINUOUS COMPOSITE
`THREE-DIMENSIONAL PRINTING
`
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Commissioner:
`
`REPLY TO OFFICE ACTION
`
`In reply to the Office Action mailed December 12, 2017 ("Office Action"), please amend
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`and reconsider the above-identified application in view of the following.
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`Claim Amendments begin on page 2 of this Reply.
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`Remarks follow the Claim Amendment section of this Reply.
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`Page 1 of 16
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`Markforged Ex. 1004
`Markforged v. Continuous Composites, IPR2022-01218
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`Application No.: 15/267,956
`Attorney Docket No.: 13087.0003-02000
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`CLAIMS LISTING:
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`The following listing of claims represents a current status of all claims in the application,
`including all amendments previously made to the claims:
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`1. (Original) A method of manufacturing of a three-dimensional object,
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`compnsmg:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material at least partially coated with the curable liquid material;
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`bonding an end point of the path of composite material to an anchor; and
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`moving the nozzle away from the anchor during discharging to pull the path of
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`composite material out of the nozzle.
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`2. (Original) The method of claim 1, wherein bonding the end point of the path
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`of composite material to the anchor includes:
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`placing the end point of the path of composite material on the anchor; and
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`aiming a curing device at the path of composite material on the anchor.
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`3. (Original) The method of claim 2, wherein aiming the curing device includes
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`aiming at least one UV light.
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`4.
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`(Original) The method of claim 3, wherein aiming the at least one UV light
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`includes aiming a plurality of lights from different angles around the nozzle.
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`5. (Original) The method of claim 3, wherein aiming the at least one UV light
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`includes aiming the at least one UV light from only a trailing side of the nozzle.
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`6.
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`(Original) The method of claim 1, wherein discharging from the nozzle the
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`path of composite material includes discharging the path of composite material through a nozzle
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`orifice having a diameter of about 2 mm.
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`Application No.: 15/267,956
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`7. (Original) The method of claim 6, wherein the continuous strand material
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`includes a plurality of strands arranged in at least one of a tow, a roving, and a weave.
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`8.
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`(Original) The method of claim 1, wherein directing the curable liquid
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`material to the nozzle includes directing a filler material at least partially coated in the curable
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`liquid material to the nozzle.
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`9.
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`(Original) The method of claim 8, wherein the filler material includes pieces
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`of fibers.
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`hollow.
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`10. (Original) The method of claim 1, wherein the continuous strand material is
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`11. (Original) The method of claim 1, further including:
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`curing a first portion of the path of composite material;
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`overlapping the first portion of the path of composite material with a second
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`portion of the path of composite material that is uncured; and
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`curing the second portion of the path of composite material while the first and
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`second portions of the path of composite material are overlapped.
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`12. (Original) The method of claim 1, wherein the overlapping includes wrapping
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`the second portion of the path of composite material around the first portion of the path of
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`composite material.
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`13. (Currently Amended) A method of manufacturing of a three-dimensional
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`object, comprising:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material at least partially coated with the curable liquid material;
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`bonding an end point of the path of composite material to an anchor;
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`moving the nozzle during discharging to cause the path of composite material to
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`extend away from the anchor; and
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`€t:lfffig exposing the curable liquid material in the path of composite material to a
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`cure energy while the nozzle is moving such that the path of composite material is
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`hardened at a fixed location in three-dimensional space without support at locations
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`between the anchor and the nozzle.
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`14. (Original) A method of manufacturing of a three-dimensional object,
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`compnsmg:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material at least partially coated with the curable liquid material;
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`curing the curable liquid material in the path of composite material; and
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`moving the nozzle during discharging to create tension in the continuous strand
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`material that remains after curing of the composite material.
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`15. (Original) A method of manufacturing of a three-dimensional object,
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`compnsmg:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`directing a filler material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material and the filler material at least partially coated with the curable
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`liquid material;
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`moving the nozzle during discharging to create the three-dimensional object; and
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`curing the curable liquid material in the path of composite material.
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`16. (Original) A method of manufacturing of a three-dimensional object,
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`compnsmg:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material at least partially coated with the curable liquid material;
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`-4-
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`Application No.: 15/267,956
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`aiming a curing device at the path of composite material to cure the curable liquid
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`material;
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`moving the nozzle during discharging to create the three-dimensional object; and
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`moving the curing device together with the nozzle.
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`17. (Original) A method of manufacturing a three-dimensional object
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`compnsmg:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material at least partially coated with the curable liquid material;
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`curing the curable liquid material in the path of composite material;
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`moving the nozzle during discharging to create the three-dimensional object; and
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`selectively cutting the continuous strand material before the continuous strand
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`material reaches the nozzle such that at least one portion of the path discharging from the
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`nozzle contains only the curable liquid material.
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`18. (Original) A method of manufacturing of a three-dimensional object,
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`compnsmg:
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`directing a curable liquid material to a nozzle;
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`directing a continuous strand material to the nozzle;
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`discharging from the nozzle a path of composite material containing the
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`continuous strand material at least partially coated with the curable liquid material;
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`adjusting a trajectory of the path of composite material after discharge from the
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`nozzle; and
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`curing the curable liquid material in the path of composite material after
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`adjusting.
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`19. (Currently Amended) A method of manufacturing a three-dimensional object
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`compnsmg:
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`discharging from a nozzle a first path of composite material and a second path of
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`composite material, the composite material of each of the first and second paths
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`Application No.: 15/267,956
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`containing a continuous strand material at least partially coated with a curable liquid
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`material;
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`curing a portion of the first path of composite material;
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`overla,pping mechanically interlocking the portion of the first path of composite
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`material with an uncured portion of the second path of composite material; and
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`curing the second path of composite material while the first and second paths of
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`composite material are overla,pped mechanically interlocked.
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`20. (Original) The method of claim 19, wherein discharging from the nozzle the
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`first path of composite material and the second path of composite material includes
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`simultaneously discharging the first and second paths of composite material.
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`Application No.: 15/267,956
`Attorney Docket No.: 13087.0003-02000
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`I.
`
`Status of the Claims
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`REMARKS
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`In the Office Action, the Examiner rejected claims 1-5, 7-9, 11, 12, and 15-20 under 35
`
`U.S.C. § 102(b) as being anticipated by U.S. Patent Application Publication No. 2003/0236588
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`("JANG"); and rejected claims 1, 6, 7, 10-14, and 18 under 35 U.S.C. § 102(b) as being
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`anticipated by U.S. Patent No. 5,340,433 ("CRUMP").
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`By this Reply, claims 13 and 19 has been amended, without adding new subject matter.
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`No claims have been cancelled. Accordingly, claims 1-20 remain pending in this application.
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`II.
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`Claim Rejection (JANG)
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`In the Office Action, the Examiner rejected claims 1-5, 7-9, 11, 12, and 15-20 as being
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`anticipated by JANG. See Office Action at 2-3. Of these claims, claims 1, 15, 16, 17, 18, and 19
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`are independent.
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`Independent claim 1 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "bonding an end point of [a] path of composite material to an
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`anchor" and "moving [a] nozzle away from the anchor during discharging to pull the path of
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`composite material out of the nozzle" (emphasis added). Because JANG does not teach or
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`suggest all features recited in independent claim 1, the rejection of independent claim 1 should
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`be withdrawn.
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`While JANG discloses a method of producing fiber reinforced composites, unlike the
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`recited features of independent claim 1, JANG does not teach "moving [a] nozzle away from the
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`anchor during discharging to pull the path of composite material out of the nozzle." To the
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`contrary, JANG expressly teaches pushing a resin-impregnated fiber 18 through a dispensing
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`head 22 onto a base member 40 using a complex system of spools 4 and rollers 6, 8, lOA, lOB,
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`Application No.: 15/267,956
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`14, 16A, 16B to control the rate that the fiber is pushed out of the head 22. An annotated version
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`of Fig. 3 of JANG, which shows the spool and roller system, is reproduced below.
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`As shown in the Fig. 3, the fiber 12 is pulled from a spool 4 through a resin bath 9 using
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`rollers 6, 8, IOA, and IOB. After exiting the resin bath 9, the impregnated fiber (also called a
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`"tow") is pushed into the dispensing head 22 and then pushed out of a dispensing nozzle 84 (see
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`Fig. 4 of JANG) of the dispensing head 22 via rollers 16A, 16B. Explaining this process, JANG
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`teaches that this spool and roller system is equipped with a motor means to "drive the movement
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`of the fiber" into and out of the dispenser head 22 at a specified rate. See JANG, paragraphs
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`[0072-0073]. JANG further teaches that relative movement of the base member 40 and the
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`dispensing head 22 is coordinated using stepper motors or other means (id. at [0076-771), and
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`that "[t]he rate at which the impregnated tow is discharged from the discharge orifice onto the
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`based member is dictated by the linear speed of the fiber tow on the surface of the roller, which
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`is driven by a motor." Id. at [0078] (emphasis added); see also id. at [0076-0077]. In this way,
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`Application No.: 15/267,956
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`the roller system pushes the fiber through the dispensing head 22 and the motors coordinate
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`relative movement of the base and dispensing head to allow for placement of the fiber at the
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`desired location without affecting the dispensing of the impregnated fiber. Because JANG does
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`not teach or suggest "moving [al nozzle away from the anchor during discharging to pull the path
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`of composite material out of the nozzle," as recited in independent claim 1, the rejection should
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`be withdrawn.
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`Moreover, beyond failing to affirmatively disclose the "pulling" feature of independent
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`claim 1, JANG expressly teaches to avoid pulling the impregnated fiber out of the dispensing
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`head 22, because it can damage the part. Specifically, JANG teaches that, after pushing the
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`impregnated fiber through the head to form the part, the fiber should be "cut off' prior to
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`movement of the dispensing head, so that additional fiber is not inadvertently pulled out of the
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`dispensing head. See JANG, paragraph [0022]; id. at [0029] (teaching that the "towpreg can be
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`cut off from the dispensing nozzle" when the dispensing nozzle is moved to a new location to
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`avoid "pull[ingl out any additional length of towpreg."). JANG explains that pulling
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`impregnated fiber out of the dispensing head can damage the part by causing "erroneous or
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`redundant disposition of towpreg along the traversal line" of the cross-section of the part. Id.
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`Because JANG does not disclose every element of any of independent claim 1, the
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`rejection of independent claim I should be withdrawn. Each of claims 2-5, 7-9, 11, and 12
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`ultimately depend from independent claim I and, thus, are allowable for at least the same reasons
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`as independent claim 1.
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`Independent claim 15 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [al nozzle a path of composite material
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`containing [al continuous strand material and [al filler material at least partially coated with [al
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`Application No.: 15/267,956
`Attorney Docket No.: 13087.0003-02000
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`curable liquid material." Because JANG does not teach or suggest all features recited in
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`independent claim 15, the rejection of independent claim 15 should be withdrawn.
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`While JANG discloses pushing of an impregnated continuous fiber through the
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`dispensing head 22, JANG fails to disclose any use of a filler, either alone or in combination
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`with a continuous fiber and a common curable liquid material. In addition, while providing a
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`background of existing technologies, JANG teaches that the use of a filler (e.g., short fibers)
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`produces parts lacking in structural integrity. See JANG, paragraph [0007]. Because JANG
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`does not teach or suggest "discharging from [a] nozzle a path of composite material containing
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`[a] continuous strand material and [a] filler material at least partially coated with [a] curable
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`liquid material," as recited in independent claim 15, the rejection of independent claim 15 should
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`be withdrawn.
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`Independent claim 16 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [a] nozzle a path of composite material
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`containing [a] continuous strand material at least partially coated with [a] curable liquid material;
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`aiming a curing device at the path of composite material to cure the curable liquid material;
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`moving the nozzle during discharging to create the three-dimensional object; and moving the
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`curing device together with the nozzle" (emphasis added). Because JANG does not teach or
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`suggest all features recited in independent claim 16, the rejection of independent claim 16 should
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`be withdrawn.
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`JANG does not teach "aiming a curing device at the path of composite material" or
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`"moving the curing device together with the nozzle." To the contrary, JANG expressly teaches a
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`use of heating elements 88 to control advancement of curing reactions. Fig. 4 of JANG, which
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`shows the heating elements 88, is reproduced below.
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`fr0. 4
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`As shown in Fig. 4, the heating elements 88 are located around the nozzle 22. JANG
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`discloses that the heating elements 88 heat the resin while the resin is inside of the nozzle 22, "so
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`that the resin substantially "solidifies" soon after dispensing." See JANG, paragraph [0074].
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`Accordingly, while the heating elements 88 of JANG might be considered a curing device that
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`moves together with the nozzle 22, JANG does not teach or suggest that the curing device can be
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`aimed, that the curing device is aimed at a path of composite material, or that the curing device is
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`aimed at a path of composite material that has been discharged from a nozzle, all of which is
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`required by independent claim 16. Because JANG does not teach or suggest all elements of
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`independent claim 16, the rejection of independent claim 16 should be withdrawn.
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`Independent claim 17 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [a] nozzle a path of composite material
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`containing [a] continuous strand material at least partially coated with [a] curable liquid material;
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`and selectively cutting the continuous strand material before the continuous strand material
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`Application No.: 15/267,956
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`reaches the nozzle such that at least one portion of the path discharging from the nozzle contains
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`only the curable liquid material" (emphasis added). Because JANG does not teach or suggest all
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`features of independent claim 17, the rejection of independent claim 17 should be withdrawn.
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`While JANG discloses a method of cutting a fiber reinforced composite, unlike the
`
`features of independent claim 17, JANG does not teach cutting a continuous strand material
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`before the continuous strand material reaches a nozzle, much less doing so such that at least one
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`portion of a path discharging from the nozzle contains only a curable liquid material. To the
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`contrary, JANG expressly teaches cutting off a towpreg from a dispensing nozzle at a finishing
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`point. See JANG, [0029]. Because JANG does not teach or suggest all elements of independent
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`claim 17, the rejection of independent claim 17 should be withdrawn.
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`Independent claim 18 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [a] nozzle a path of composite material
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`containing [a] continuous strand material at least partially coated with [a] curable liquid material;
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`adjusting a trajectory of the path of composite material after discharge from the nozzle; and
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`curing the curable liquid material in the path of composite material after adjusting" (emphasis
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`added). While JANG discloses pushing of an impregnated continuous fiber through the
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`dispensing head 22, JANG fails to disclose any trajectory being adjusted after discharge or any
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`curing after trajectory adjusting. Because JANG does not teach or suggest all features recited in
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`independent claim 18, the rejection of independent claim 18 should be withdrawn.
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`Independent claim 19 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [a] nozzle a first path of composite material
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`and a second path of composite material; curing a portion of the first path of composite material;
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`mechanically interlocking the portion of the first path of composite material with an uncured
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`portion of the second path of composite material; and curing the second path of composite
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`material while the first and second paths of composite material are mechanically interlocked."
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`While JANG discloses the dispensing of a new layer of towpreg and the bonding to a
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`previously deposited layer to form a multiple-layer object, JANG fails to disclose any
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`mechanical interlocking of an uncured path of composite material with a cured path. Because
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`JANG does not teach or suggest all features recited in independent claim 19, the rejection of
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`independent claim 19 should be withdrawn. Claim 20 depends from independent claim 19 and,
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`thus, is allowable for at least the same reasons as independent claim 19.
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`III.
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`Claim Rejection (CRUMP)
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`In the Office Action, the Examiner rejected claims 1, 6, 7, 10-14, and 18 as being
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`anticipated by CRUMP. See Office Action at 3. Of these claims, claims 1, 13, 14, and 18 are
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`independent.
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`As discussed above, independent claim 1 recites a method of manufacturing a three(cid:173)
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`dimensional object that comprises, among other things, "bonding an end point of [a] path of
`
`composite material to an anchor" and "moving [a] nozzle away from the anchor during
`
`discharging to pull the path of composite material out of the nozzle" (emphasis added). Because
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`CRUMP does not teach or suggest all features recited in independent claim 1, the rejection of
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`independent claim 1 should be withdrawn.
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`While CRUMP discloses a method of dispensing a liquified material as a solidified strand
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`into free space, unlike the features of independent claim 1, CRUMP does not teach "moving [a]
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`nozzle away from the anchor during discharging to pull the path of composite material out of the
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`nozzle." To the contrary, CRUMP does not teach use of a composite material at all. In addition,
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`CRUMP expressly teaches pushing the liquified material through a nozzle 4 and onto a base
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`plate 10 using a complex arrangement of drive rod 52, pivot link 70, ratchet head 72, and ratchet
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`teeth 74. An annotated version of Fig. 3 of CRUMP, which shows the arrangement, is
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`reproduced below.
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`As shown in the Fig. 3, a supply rod 42 is pushed by the drive rod, pivot link, ratchet
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`head, and ratchet teeth arrangement into a heating head 84, where the supply rod 42 is melted.
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`The liquified material is then pushed through a flow passage 94 to an orifice 98 in the nozzle 4.
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`Because CRUMP does not teach or suggest "moving [al nozzle away from the anchor during
`
`discharging to pull the path of composite material out of the nozzle," as recited in independent
`
`claim 1, the rejection of independent claim I should be withdrawn. Each of claims 6, 7, and I 0-
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`12 ultimately depend from independent claim I and, thus, are allowable for at least the same
`
`reasons as independent claim 1.
`
`Independent claim 13 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from a nozzle a path of composite material; and
`
`exposing a curable liquid material in the path of composite material to a cure energy while the
`
`nozzle is moving such that the path of composite material is hardened at a fixed location in three(cid:173)
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`dimensional space without support at locations between an anchor and the nozzle" ( emphasis
`
`added). While CRUMP discloses "instantaneous solidification of [a] material, even in free
`
`space," it is accomplished by "the use of coolant." See CRUMP, col. 21, ll. 19-23. CRUMP
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`does not teach or suggest exposing anything to a cure energy to cause it to harden, much less a
`
`curable liquid material in a path of a composite material. In contrast, CRUMP teaches the
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`removal of energy from a material to cause its solidification. Because CRUMP does not teach or
`
`suggest all features recited in independent claim 13, the rejection of independent claim 13 should
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`be withdrawn.
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`Independent claim 14 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [a] nozzle a path of composite material
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`containing; and moving the nozzle during discharging to create tension in [a] continuous strand
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`material that remains after curing of the composite material" (emphasis added). As described
`
`above, CRUMP does not teach or suggest discharging a composite material, but instead only a
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`liquid material that solidifies upon discharging. In addition, there is no teaching or suggestion
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`within CRUMP of tension creation or tension that remains in a continuous strand material after
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`curing. Because CRUMP does not teach or suggest all features recited in independent claim 14,
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`the rejection of independent claim 14 should be withdrawn.
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`-15-
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`Application No.: 15/267,956
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`Independent claim 18 recites a method of manufacturing a three-dimensional object that
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`comprises, among other things, "discharging from [a] nozzle a path of composite material
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`containing [a] continuous strand material at least partially coated with [a] curable liquid material;
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`adjusting a trajectory of the path of composite material after discharge from the nozzle; and
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`curing the curable liquid material in the path of composite material after adjusting" (emphasis
`
`added). CRUMP fails to disclose any trajectory being adjusted after discharge or any curing
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`after trajectory adjusting. Because CRUMP does not teach or suggest all features recited in
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`independent claim 18, the rejection of independent claim 18 should be withdrawn.
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`IV.
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`Conclusions
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`In view of the foregoing remarks, Applicant respectfully requests reconsideration and
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`reexamination of this application and the timely allowance of all pending claims.
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`If the Examiner believes a telephone conversation might advance prosecution, the
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`Examiner is invited to call Applicant's undersigned representative at 202.641.7683.
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`The Office Action contains numerous characterizations of the claims and the cited
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`references with which Applicant does not necessarily agree. Unless expressly stated, Applicant
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`declines to subscribe to any of these characterizations in the Office Action.
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`Respectfully submitted,
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`Dated: December 20, 2017
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`Respectfully submitted,
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`By /Ryan C. Stockett/
`Ryan C. Stockett
`Reg. No. 53,642
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`-16-
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`Page 16 of 16
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`Markforged Ex. 1004
`Markforged v. Continuous Composites, IPR2022-01218
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`



