Ex parte YIN - Page 7




          Appeal No. 1999-0007                                                        
          Application 08/688,218                                                      


          The geometry, simulation model and schematic symbol databases               
          (i.e., libraries) are the embodiment of the integrated circuit              
          being created (column 8, lines 44-53).  Upton states:                       
                    If a version of the module [integrated                            
                    circuit] is needed in a different rule set,                       
                    a design rule variable file containing                            
                    these new values can be substituted for the                       
                    original file.  The module compiler 68 can                        
                    produce the geometry simulation model,                            
                    schematic symbol and transistor model                             
                    generators (65, 69, 67 and 70,                                    
                    respectively) embodying the constraints as                        
                    specified for any given design rule set.                          
                    [Column 9, lines 26-32.]                                          
                                                                                     
          Thus, Upton does not translate the databases embodying a first              
          integrated circuit (of a first technology) to databases embodying           
          a second integrated circuit (of a second technology).  Rather,              
          Upton substitutes a different rule set into the design program,             
          and generates databases for an integrated circuit ab initio, not            
          by translation from existing first integrated circuit databases.            
               Appellant further argues that Dai makes no teaching or                 
          suggestion that the place and route database is also used to map            
          into another place and route database for a different                       
          manufacturing process (brief-page 14).  Still further, Appellant            
          argues, nothing in Dai teaches or suggests mapping between two              

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