Accordingly, the parties have sufficiently demonstrated that Boutros claim 29 does not anticipate
Lok claim 1. The parties further submit that the "together with" limitation is not taught or
suggested by Boutros claim 29 or in Boutros' disclosure (Paper 58 at 7). The parties further
submit that Lok claim I would not have been obvious given Boutros claim 29 and that the parties
are unaware of any prior art that would render Lok claim I obvious in view of Boutros claim 29
(Paper 58 at 6 and 7).
Neither of Boutros' dependent claims 30 or 31 or Lok's claims that depend on Lok claims
I or 13 recite the missing features from Boutros claim 29, or Lok claims I and 13. Accordingly,
the joint preliminary motion I is granted.
No interference-in-fact motion with respect to Count 2
Lok has filed a revised unopposed preliminary motion that there is no interference-in-fact
between any Lok claim that corresponds to count 2 and any Boutros claim that corresponds to
count 2.
As with Lok claim 1, Lok claim I I includes the "together with" (also referred to as "the
together" feature) limitation by claiming that the contact unit and the circuit board are attached
and that the "printed circuit board together with the contact unit is slidably received in the slot."
As pointed out by Lok, Boutros claim 32 fails to recite the "together with" limitation. Instead,
Boutros claim 32 recites that the PCB and the contact unit are slidably received, but fails to recite
that the PCB and the contact unit are together inserted into the plug.
Furthermore, Lok submits that the function of securely retaining the PCB and contact unit
invokes 35 U.S.C. 112, 16, such that the corresponding structure associated with the function of
securely retaining the PCB and the contact unit is different with respect to Boutros' claim 32
7
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