Appeal No. 1997-1197
Application 08/130,255
the structure in Kajihara is an equivalent, without
particularly pointing out what structure in figures 10a and
10b is the structure required to perform the claimed functions
or why the structure in Kajihara is not the same or an
equivalent.
For these two reasons, the issue of structure and
equivalents under § 112, sixth paragraph, should not be an
issue in any judicial review. Without waiving this position,
for Appellants' benefit we comment on why the means-plus-
function language of claim 9 does not distinguish over
Kajihara.
Kajihara performs the functions of the "memory controller
means" for the reasons stated in connection with claim 16.
As to the structure, the only described structure
absolutely required to perform the function of "sequentially
writing said pixel data to said memory in a first sequence" is
address logic having a write signal which can generate one
write sequence and the only structure absolutely required to
perform the function of "selectively reading said pixel data
from said memory in said first sequence . . . or reading said
pixel data in a second sequence" is address logic having a
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