Ex parte TOWFIQ - Page 9




          Appeal No. 1999-2720                                                        
          Application No. 08/580,965                                                  
          complete copies of versions, one of ordinary skill in this art              
          would not have been motivated to combine Tichy and Ambriola.                


               In response to the Examiner's statement that "whether the              
          versions . . . are stored in the form of deltas or                          
          complete/intact copies is not claimed, and thus does not                    
          preclude the application of the Ambriola reference."                        
          Appellant asserts8 that technical distinctions between                      
          references that would preclude a suggestion or motivation for               
          combining references do not need to be recited in the claims.               
               Appellant also argues that the Examiner has not                        
          considered Ambriola as a whole in conformance with the                      
          requirements of                                                             
          35 U.S.C. § 103 and MPEP § 2141.01.  Specifically, Appellant                
          points to the Examiner's alleged attempt to separate this                   
          reference's bringover and storeback commands from its delta                 
          version control method.                                                     
               At page 5 of his Reply Brief, Appellant asserts that the               
          Examiner's finding that a version/revision of Tichy can be                  
          represented in a delta or a complete form, applies hindsight                


               8Reply brief, page 3                                                   
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