Remarks
`
`The Pending Claims
`
`Claims 26-45 are currently pending. Reconsideration and allowance of the pending
`
`claimsis respectfully requested.
`
`Summaryof the Office Action
`
`Allowable Subject Matter
`
`Pending correction of the Reissue Declaration, claims 28-31, 33 and 36-40 will be
`
`objected to as being dependent upona rejected base claim, but would be allowable if
`
`rewritten in independent form includingall of the limitations of the base claim and any
`
`intervening claims.
`
`Defective Reissue Declaration
`
`The reissue oath/declaration filed with this application is defective (see 37 CFR 1.175
`
`and MPEP§ 1414) becauseof the following: As per MPEP 1414(11), anyerrorin the
`
`claims mustbe identified by reference to the specific claim(s) and the specific claim
`
`language wherein lies the error. The examiner notes that the Applicant correctly identifies
`
`original claim 1. However, the error statement does not identify the specific claim
`
`language in original claim 1 whereinlies the error. Thatis, reference to "echo
`
`cancellation unit” is considered a narrowing limitation since it was not in original Claim
`
`1. Since the instant reissue is a broadening reissue application, Applicant must identify
`
`the languagein original claim 1, that the applicant seeks to broaden. The examiner
`
`recommendsleaving the statement regarding "echo cancellation” in the statement but to
`
`also add an original claim limitation (from claim 1) that was broadened.
`
`Rejection under 35 U.S.C. 251
`
`

`

`Claims 26-45 are rejected as being based upon a defective reissue declaration under 35
`
`U.S.C. 251 as set forth above. See 37 CPR 1.175.
`
`Rejection under 35 U.S.C. 103
`
`Claims 26, 32, 34 and 41-45 are rejected under pre-AIJA 35 U.S.C. 103(a) as being
`
`unpatentable over Liet al., “A Portable USB-Based Microphone Array Device For
`
`Robust Speech Recognition”, in view of Erten US. Patent 6,236,862.
`
`Claims 27 and 35 is/are rejected under pre-AJA 35 U.S.C. 103(a) as being unpatentable
`
`over Li et al., “A Portable USB-Based Microphone Array Device For Robust Speech
`
`Recognition”, in view of Erten US. Patent 6,236,862, in view of Kimetal. US. Patent
`
`Pub. 2009/0279714.
`
`Allowable Subject Matter
`
`Theoffice action states: “Pending correction of the Reissue Declaration, claims 28-31,
`
`33 and 36-40 will be objected to as being dependent upon a rejected base claim, but
`
`would beallowable if rewritten in independent form including all of the limitations
`
`of the base claim and any intervening claims.”
`
`Applicant appreciates identification of allowable claims by the examiner.
`
`However, applicant does not wish to narrow the independentclaims as suggested by the
`
`examiner. Instead, applicant will present arguments to overcomethe rejections underpre-
`
`AIA 35 U.S.C. 103(a) without making any amendmentsto the claims.
`
`The office action further states: “The reissue oath/declaration filed with this
`
`application is defective (see 37 CFR 1.175 and MPEP§ 1414) because of the
`
`following: As per MPEP 1414(11), any errorin the claims mustbeidentified by
`
`reference to the specific claim(s) and the specific claim language whereinlies the
`
`

`

`error. The examiner notes that the Applicant correctly identifies original claim 1.
`
`However,the error statement does not identify the specific claim language in
`
`original claim 1 wherein lies the error. That is, reference to "echo cancellation unit”
`
`is considered a narrowing limitation since it was not in original Claim 1. Since the
`
`instant reissue is a broadening reissue application, Applicant must identify the
`
`languagein original claim 1, that the applicant seeks to broaden. The examiner
`
`recommendsleaving the statement regarding "echo cancellation" in the statement
`
`but to also add an original claim limitation (from claim 1) that was broadened.”
`
`In response to the above objection, applicant has submitted a new reissue
`
`declaration prepared as per guidelines given in the office action. Applicant respectfully
`
`submits that the reissue declaration is now compliant as per 37 CFR 1.175 and MPEP §
`
`1414.
`
`The office action further states: “Claims 26-45 are rejected as being based upon a
`
`defective reissue declaration under 35 U.S.C. 251 as set forth above. See 37 CPR
`
`1.175.”
`
`In response to the above, applicant has submitted a new reissue declaration
`
`prepared as per guidelines given in the office action. Applicant therefore respectfully
`
`requests that the rejection of claims 26-45 under 35 U.S.C. 251 be reconsidered and
`
`withdrawn.
`
`The office action further states: “Claims 26, 32, 34 and 41-45 are rejected underpre-
`
`AIA 35 U.S.C. 103(a) as being unpatentable overLiet al., “A Portable USB-Based
`
`Microphone Array Device For Robust Speech Recognition’, in view of Erten US.
`
`Patent 6,236,862.”
`
`In response to the above, applicant submits that Li, in view of Erten, does not
`
`teach or suggest the following limitations in claim 26:
`
`

`

`“estimating a location of said target sound signal from said received sound signals
`
`by said sound source localization unit;”
`
`“performing adaptive beamformingfor steering a directivity pattern of said array
`
`of said soundsensorsin a direction of said location of said target sound signal by
`
`said adaptive beamforming unit, wherein said adaptive beamforming unit
`
`enhancessaid target sound signal and partially suppresses said ambient noise
`
`signals;”
`
`Therefore, applicant submits that claim 26 is not obvious overLi, in view of
`
`Erten.
`
`By wayof explanation, claim 26 discloses a sound source localization unit 202
`
`either as an independent module as shownin FIG. 2 of applicant’s originally filed
`
`application, or as a module integrated into a digital signal processor (DSP) 1403 as
`
`shownin FIG. 14 of applicant’s originally filed application.
`
`Hardware structure of system disclosed in claim 26:
`
`ht
`
`
`poem
`ARRAY OF SHIN
`SENSORS
`
` SCHINT! SCHEIN
`EURCALIZATHON UNIT
`
`
`
`S¥YATHESE FILTER
`
`FE2
`
`NCHSE RECHTER
`UNTE
`
`
`
`

`

`COMMUNICATION
`INTERFACE
`
`1403
`
`1404
`
`MICROPHONE
`
`
`
`AMPLIFIER,
`
`
`(IGITAL SIGNAL |
`PROCESSOR
`
`: PLASH MEMORY
`
`AUDIO CODEC
`
`MICROPHONE.—
`
`AMPLIFIER
`
`MCROPHONE
`
`AMPLAMER
`
`SWITCHPOWER
`LINEARroe i
`
`REGULATOR
`
`
`BATTERY FIG.14
`
`,
`
`?
`:
`sein
`g
`peewee‘row RECATOR
`
`FIG. 2 above comprises a sound source localization unit 202. Furthermore, FIG.
`
`14 comprises a digital signal processor (DSP) 1403. Furthermore, column 15, lines 27-29
`
`of the originally filed application states: “The DSP 1403 implements the sound source
`
`localization unit 202, the adaptive beamforming unit 203, and the noise reduction
`
`unit 207.”
`
`Furthermore, column 2, lines 30-33 of the originally filed application states: “The
`
`sound source localization unit estimates a spatial location of the target sound signal from
`
`the received soundsignals, for example, using a steered response power-phase
`
`transform’. Furthermore, column 4, lines 31-34 of the originally filed application states:
`
`“FIG. 8 exemplarily illustrates a method for estimating a spatial location of the target
`
`soundsignal from the target sound source by a soundsource localization unit using a
`
`steered response power-phase transform.” After the estimation of spatial location of the
`
`target sound signal by the sound source localization unit, the adaptive beamforming unit
`
`steers a directivity pattern of the array of sound sensorsin a direction of the estimated
`
`spatial location of the target soundsignal.
`
`

`

`Li does not disclose a sound source localization unit between an array of sound
`
`sensors and an adaptive beamforming unit as shown in FIG. 2 above. Furthermore, Li
`
`does not disclose that the estimation of spatial location of the target sound signal by the
`
`sound source localization unit is performed before the signal reaches the beamforming
`
`unit. Furthermore, Li does not disclose that the beamforming unit steers the directivity
`
`pattern of the array of sound sensorsin the direction of estimated spatial location of the
`
`target sound signal.
`
`In contrast, Li discloses a hardware construction as shown below:
`
`a. SYSTEM DESCRIPTION
`
`Finsh memory
`
`“beosplefaer =
`O “pambter y Spot
`
`Ki emolifier " Forming
`
`-
`
`MGierophone
`
`Figure 2. Ubisiration of the hardware structure
`
`Asseen in the above figure, the signals from the array of sound sensorsdirectly
`
`feed into the beam-forming unit of the digital signal processor. The beamforming unit in
`
`Li steers the directivity pattern of the array of sound sensorsin a direction of spatial
`
`location of the target sound signal whichis not estimated previously by the sound source
`
`localization unit. Furthermore, Li does not disclose that the sound source localization unit
`
`estimates the spatial location of the target sound signal from the received sound signals
`
`using the steered response power-phasetransform.
`
`The office action in page 27 states that paragraphs [0025] and [0061] of Kim
`
`discloses asound source localizer which determines the direction of the sound source
`
`using a Steered Response Power (SRP) - PHATalgorithm. Applicant disagrees and
`
`7
`
`

`

`presents the following arguments. Applicant does not use a Generalized Cross-
`
`Correlation (GCC)-Phase Transform (PHAT)algorithm in his sound source localization
`
`unit 202.
`
`In contrast, Kim discloses, inter alia, a hybrid sound sourcelocalizer that uses a
`
`combination of a Generalized Cross-Correlation (GCC)-Phase Transform (PHAT)
`
`algorithm and the Steered Response Power (SRP)- PHATalgorithm; see Kim paragraph
`
`[0025], which states: “Another aspect of the present invention provides a hybrid sound
`
`source localization apparatus and method of a robot rapidly determining the direction of
`
`a sound source using a Generalized Cross-Correlation (GCC)-Phase Transform (PHAT)
`
`algorithm and accurately localizing the sound source in the sound source direction using
`
`a Steered Response Power (SRP)-PHAT algorithm,” and Kim paragraph [0061], which
`
`states: “When sound is picked up through the microphone unit 110, the sound source
`
`localizer 120 determines the direction of the sound source using a Generalized Cross-
`
`Correlation (GCC)-Phase Transform (PHAT) algorithm, and the position of the sound
`
`source in three-dimensional space in the determined sound source direction using a
`
`Steered Response Power (SRP)-PHAT algorithm.” Kim discouragesthe use of only the
`
`Steered Response Power (SRP) - PHATalgorithm at manyplacesin his patent
`
`application. For example, Kim paragraph [0022] states: “The method using the SRP-
`
`PHAT algorithm involves too much computation to process in a real-time system, and
`
`thus, it is difficult to apply the method to a miniaturized robot.” Furthermore, Kim
`
`Paragraph [0019] states: “The SRP-PHAT algorithm is difficult to use to localize a sound
`
`source in real time but has excellent sound source localization performancein a three-
`
`dimensional space.” Furthermore, Kim paragraph [0014] states: “However, the SRP-
`
`PHAT algorithm involves a large amount of computation. Thus, the SRP-PHAT
`
`algorithm is difficult to use in real time but has better sound source localization
`
`performance than the GCC-PHAT algorithm.” Therefore, Kim teaches away from the
`
`recitation in claim 26. Furthermore, even if one of ordinary skill in the art weretostill
`
`combine Li, Erten and Kim asstated in the office action, the combination would not be
`
`the same as whatis recited in claim 26 as the sound source localizer would include a
`
`Generalized Cross-Correlation (GCC)-Phase Transform (PHAT)algorithm.
`
`

`

`Therefore, Li, in view of Erten, and further in view of Kim (if combined with Li
`
`and Erten as stated in page 27), does not teach or suggest the following limitation in
`
`claim 26:
`
`“estimating a location of said target sound signal from said received sound signals
`
`by said sound source localization unit;”
`
`Furthermore, as recited in claim 26, there is a sound source localization unit 202
`
`in betweenthe array of sound sensors 201 and the adaptive beamforming unit 203.
`
`Therefore, in claim 26, the adaptive beamforming unit 203 performs adaptive
`
`beamforming and steers the directivity pattern of the array of sound sensorsin the
`
`direction of spatial location of the target sound signal previously estimated by the sound
`
`source localization unit 202. In contrast, the beamforming unit in Li is directly connected
`
`to the array of sound sensorsandsteers the directivity pattern of the array of sound
`
`sensors in a direction of spatial location of the target sound signal which is NOT
`
`estimated previously by a sound source localization unit.
`
`Furthermore, the adaptive beamforming unit 203 in claim 26 steers the directivity
`
`pattern of the microphonearray 201 in a direction of the spatial location of the target
`
`sound signal, thereby enhancing the target sound signal and partially suppressing the
`
`ambient noise signals. Furthermore, the adaptive beamforming unit 203 in claim 26 is
`
`structurally and functionally different from the beamforming unit in Li. As seen in FIG. 2
`
`of the originally filed application, the adaptive beamforming unit 203 comprises a fixed
`
`beamforming unit 204, a blocking matrix 205, and an adaptivefilter 206. The fixed
`
`beamforming unit 204 is functionally same as the beamforming unit in Li. The similarity
`
`endsthere. The blocking matrix 205 blocks the target sound signal from the target sound
`
`source and feeds the ambient noise signals to the adaptive filter 206 to minimize the
`
`effect of the ambient noise signals on the enhanced target sound signal. The adaptive
`
`filter 206 The adaptive filter 206 adaptively filters the ambient noise signals in response
`
`to detecting presence or absenceofthe target sound signal in the sound signals received
`
`

`

`from the disparate sound sources; see FIG. 10, and column 12, lines 52-61 of applicant’s
`
`original application. The additional modules comprising the blocking matrix 205 and the
`
`adaptive filter 206, and corresponding functionality of partially suppressing the ambient
`
`noise signals (see column6, lines 60-64 of applicant’s original application) is NOT
`
`disclosed in Li. Therefore, the following limitation in claim 26 is not taught or suggested
`
`in the IEEE paper:
`
`“performing adaptive beamformingfor steering a directivity pattern of said array
`
`of said soundsensorsin a direction of said spatial location of said target sound
`
`signal by said adaptive beamforming unit, wherein said adaptive beamforming
`
`unit enhancessaid target sound signal and partially suppresses said ambient noise
`
`signals;”
`
`Note: said spatial location = location estimated by the sound source localization
`
`unit in the previous limitation.
`
`Furthermore, claim 26 discloses a two-step noise reduction process (see column 6,
`
`lines 60-64 and column 7, lines 9-11 in the originally filed application):
`
`(i) Step 1 of noise reduction process:
`
`“performing adaptive beamforming for steering a directivity pattern of said
`
`array of said sound sensorsin a direction of said spatial location of said target
`
`sound signal by said adaptive beamforming unit, wherein said adaptive
`
`beamforming unit enhances said target sound signal and partially suppresses
`
`said ambient noise signals;” and
`
`(ii) Step 2 of noise reduction process:
`
`“a noise reduction unit that suppresses said ambient noise signals for further
`
`enhancingsaid target sound signal”.
`
`10
`
`

`

`The office action in page 24 states that Li discloses the two-step noise reduction
`
`process as in claim 26. Applicant disagrees and presents arguments to show that Li
`
`performs only a one-step noise reduction in the noise reduction unit. There is no partial
`
`noise suppression in the beamforming unit in Li. In Li, noise reduction is performed only
`
`in the noise reduction unit; see Section 3. Noise Reduction in Li, which states: “The
`
`noisy-speech spectrum passes through the Wienerfilter, which then generates an estimate
`
`of the clean speech spectrum.”; see equivalent of this in the noise reduction unit 207 of
`
`claim 26, in column,lines , which states: “/n an embodiment, the noise reduction is
`
`performed using the Wiener-filter based noise reduction algorithm.”. Therefore, Li only
`
`performs the second step of noise reduction in claim 26.
`
`In view of the above arguments, applicant submits that Li, in view of Erten, and
`
`further in view of Kim (if combined with Li and Erten as stated in page 27), does not
`
`teach or suggest the following limitations in claim 26:
`
`“estimating a location of said target sound signal from said received sound signals
`
`by said sound source localization unit;”
`
`“performing adaptive beamformingfor steering a directivity pattern of said array
`
`of said soundsensorsin a direction of said location of said target sound signal by
`
`said adaptive beamforming unit, wherein said adaptive beamforming unit
`
`enhancessaid target sound signal and partially suppresses said ambient noise
`
`signals;”
`
`Therefore, even if Li, Erten and Kim (Gif combined with Li and Erten as stated in
`
`page 27) are combined asstated in the office action, the combination would notarrive at
`
`the recitation in claim 26. Therefore, claim 26 is non-obvious over a combination of Li,
`
`Erten and Kim (if combined with Li and Erten as stated in page 27).
`
`Applicant therefore respectfully requests that the rejection of claim 26 underpre-
`
`AJA 35 U.S.C. 103(a) be reconsidered and withdrawn.
`
`11
`
`

`

`Claim 34 recites a system that is used to perform the method of claim 26.
`
`Therefore, in view of same arguments as for claim 26, applicant submits that Li, in view
`
`of Erten, and further in view of Kim (if combined with Li and Erten as stated in page 27),
`
`does not teach or suggest the following limitations in claim 34:
`
`“a digital signal processor, said digital signal processor comprising:
`
`a sound source localization unit that estimates a location of said target
`
`sound signal from said received sound signals, by determining a delay
`
`between each of said sound sensors and an origin of said array of said
`
`sound sensors as a function of distance between each of said sound sensors
`
`and said origin, a predefined angle between each of said sound sensors and
`
`a reference axis, and an azimuth angle between said reference axis and
`
`said target sound signal, whensaid target sound source that emits said
`
`target sound signalis in a two dimensionalplane, wherein said delayis
`
`represented in terms of number of samples, and wherein said
`
`determination of said delay enables beamforming for said array of sound
`
`sensors in a plurality of configurations;
`
`an adaptive beamforming unit that steers directivity pattern of said array
`
`of said sound sensorsin a direction of said location of said target sound
`
`signal, wherein said adaptive beamforming unit enhancessaid target sound
`
`signal and partially suppresses said ambient noise signals;”
`
`Applicant therefore respectfully requests that the rejection of claim 34 underpre-
`
`AJA 35 U.S.C. 103(a) be reconsidered and withdrawn.
`
`Claim 42 also recites a system that is used to perform the method of claim 26.
`
`Therefore, in view of same arguments as for claim 26, applicant submits that Li, in view
`
`12
`
`

`

`of Erten, and further in view of Kim (if combined with Li and Erten as stated in page 27),
`
`does not teach or suggest the following limitations in claim 42:
`
`“a digital signal processor, said digital signal processor comprising:
`
`a sound source localization unit that estimates a location of said target
`
`sound signal from said received sound signals by determining a delay
`
`between each of said sound sensors and a reference point of said array of
`
`said sound sensors as a function of distance between each of said sound
`
`sensors and said reference point and an angle of each of said sound
`
`sensors biased from a reference axis;
`
`a beamforming unit that enhancessaid target sound signal and partially
`
`suppresses said ambient noise signals;”
`
`Applicant therefore respectfully requests that the rejection of claim 42 underpre-
`
`AJA 35 U.S.C. 103(a) be reconsidered and withdrawn.
`
`Claims 28-33 are dependent on claim 26. Claims 36-41 are dependent on claim
`
`34. Claims 43-45 are dependent on claim 42. Since claims 26, 34 and 42 are non-obvious
`
`over Li, in view of Erten, and further in view of Kim (if combined with Li and Erten as
`
`stated in page 27), claims 28-33, 36-41 and 43-45 are also non-obvious overLi, in view
`
`of Erten, and further in view of Kim (if combined with Li and Erten as stated in page 27).
`
`Applicant therefore respectfully requests that the rejection of claims 28-33, 36-41 and 43-
`
`45 under pre-AIA 35 U.S.C. 103(a) be reconsidered and withdrawn.
`
`The office action further states: “Claims 27 and 35is/are rejected under pre-AIA 35
`
`U.S.C. 103(a) as being unpatentable over Liet al., “A Portable USB-Based
`
`Microphone Array Device For Robust Speech Recognition’, in view of Erten US.
`
`Patent 6,236,862, in view of Kim et al. US. Patent Pub. 2009/0279714.”
`
`13
`
`

`

`In an earlier part of this response, arguments were presented to illustrate that Li,
`
`in view of Erten, in view of Kim, does not teach or suggest the following limitations in
`
`claim 26:
`
`“estimating a location of said target sound signal from said received sound signals
`
`by said sound source localization unit;”
`
`“performing adaptive beamformingfor steering a directivity pattern of said array
`
`of said soundsensorsin a direction of said location of said target sound signal by
`
`said adaptive beamforming unit, wherein said adaptive beamforming unit
`
`enhancessaid target sound signal and partially suppresses said ambient noise
`
`signals;”
`
`Arguments were also presentedto illustrate that Li, in view of Erten, and further
`
`in view of Kim, does not teach or suggest the following limitations in claim 34:
`
`“a digital signal processor, said digital signal processor comprising:
`
`a sound source localization unit that estimates a location of said target
`
`sound signal from said received sound signals, by determining a delay
`
`between each of said sound sensors and an origin of said array of said
`
`sound sensors as a function of distance between each of said sound sensors
`
`and said origin, a predefined angle between each of said sound sensors and
`
`a reference axis, and an azimuth angle between said reference axis and
`
`said target sound signal, whensaid target sound source that emits said
`
`target sound signalis in a two dimensionalplane, wherein said delayis
`
`represented in terms of number of samples, and wherein said
`
`determination of said delay enables beamforming for said array of sound
`
`sensors in a plurality of configurations;
`
`14
`
`

`

`an adaptive beamforming unit that steers directivity pattern of said array
`
`of said sound sensorsin a direction of said location of said target sound
`
`signal, wherein said adaptive beamforming unit enhancessaid target sound
`
`signal and partially suppresses said ambient noise signals;”
`
`Therefore, claims 26 and 34 are non-obvious over Li, in view of Erten, and
`
`further in view of Kim. Claim 27 is dependent on claim 26. Claim 35 is dependent on
`
`claim 34. Since claims 26 and 34 are non-obvious overLi, in view of Erten, and further
`
`in view of Kim, claims 27 and 35 are also non-obvious over Li, in view of Erten, and
`
`further in view of Kim.
`
`Applicant therefore respectfully requests that the rejection of claims 27 and 35
`
`under pre-AIA 35 U.S.C. 103(a) be reconsidered and withdrawn.
`
`Conclusion
`
`Since there are no claim amendments, applicant respectfully requests that this
`
`response be considered under “After Final Consideration Pilot Program 2.0”.
`
`Furthermore, applicant respectfully requests that a timely Notice of Allowance be issued
`
`in this case. In the interest of compact prosecution,if the prosecution of the application
`
`can be advancedorif a claim may be made potentially allowable by an Examiner’s
`
`amendment, applicant requests Examiner Escalante to call the undersigned with the
`
`proposed amendment.
`
`Date: July 29, 2020
`
`Correspondence Address
`Lipton, Weinberger & Husick
`36 Greenleigh Drive
`Sewell, NJ 08080
`
`15
`
`Respectfully submitted,
`
`/a tankha/
`Ashok Tankha
`Attorney For Applicant
`Reg. No. 33,802
`
`

`

`Phone: 856-266-5145
`Fax: 856-374-0246
`Email: ash@ipprocurement.com
`
`16
`
`