Appeal No. 2002-0270
Application No. 09/099,584
Appellants contend in the Brief (at 5) that the examiner has neglected to point
out any teaching of Aho that may correspond to the “fixed processor resource” as
claimed. The examiner, in the Answer (at 4), replies that the “three-address statement,”
an intermediate representation code which is translated from a computer program, is a
closed form of fixed processor resource because it will be used to map into fixed
processor registers. As support for the position, the examiner also relies on a portion of
the Aho reference that was not applied in the Final Rejection. (Answer at 9-10.)
Appellants respond, in turn, that the three-address statement of Aho is merely an
intermediate code representation of program statements using variables, and nowhere
does the reference teach that the intermediate code variables correspond to fixed
processor registers. According to appellants, register allocation is performed later, after
the optimizations that use the three-address statements. (Reply Brief at 2-3.)
We find appellants’ arguments to be persuasive. As shown in Figure 10.3
(p. 590) of Aho, the code optimization using the three address-statements occurs prior
to code generation for the target machine. See Aho, ¶ bridging pp. 588-89. The
intermediate code can be relatively independent of the target machine, and may be
independent of word size of the target machine. Id. at 590. The register allocation
discussed in the Answer occurs in Chapter 9 of Aho, under “Code Generation,” as
referenced in “Code Optimization” Chapter 10, at page 589. The code generator
discussed in Chapter 9 produces the target program from the transformed intermediate
code.
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