Ex Parte Luo - Page 11


                   Appeal No. 2006-1618                                                                                             
                   Application No. 10/046,797                                                                                       


                   data structure to represent boundary information, and (2) receiving input of a                                   
                   contour image and transforming the image into a set of quantized transform                                       
                   coefficients and segment data [non-final rejection, page 6].  The examiner then                                  
                   asserts "that format changes in images and videos are very well-known in the                                     
                   art" [non-final rejection, page 7].  The examiner concludes that it would have                                   
                   been obvious to one of ordinary skill in the art at the time of the invention to                                 
                   modify Kim to convert from one format to another to ensure compatibility with                                    
                   various systems [id.].                                                                                           
                           Appellant notes that the claim recites converting graphical information of a                             
                   data structure in combination with encoding vertices in the data structure [brief,                               
                   page 11].  Appellant notes that the quantized transform coefficients and segment                                 
                   data in Kim are not encoded into a data structure that is converted [id.].  Also,                                
                   appellant disagrees with the examiner's assertion that converting graphical                                      
                   information of the data structure from a first format to a second, different format is                           
                   well known in the art [id.].                                                                                     
                           The examiner responds that the term "data structure" is broad and can                                    
                   emcompass any method of storing data, including the quantized transform                                          
                   coefficients of Kim [answer, page 7].  According to the examiner, Kim's transform                                
                   coefficients constitute data to be transmitted and must have some sort of                                        
                   inherent structure; otherwise, the data cannot be read [id.].  The examiner also                                 
                   contends that Kim even meets a second, narrower definition of "data structure"                                   




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