Appeal No. 1996-2195
Application 08/120,911
Segers. Appellants argue that the modification proposed by
the Examiner is expressly prohibited by the Watkins system.
Appellants argue that the entirety of the Watkins disclosure
is directed to specialized hardware and software improvements
in computer systems that function to control data movements
between external devices and main memory. In particular,
Watkins is concerned
with the problem of maintaining data consistency between the
I/O cache and the CPU cache, which is collectively called
consistency controls. Appellants argue that it is improper
under 35 U.S.C. § 103 to ignore the invention set forth by the
primary reference in order to support a purported obvious
modification of the reference in order to meet the claimed
invention. Appellants further emphasize this point in the
reply brief. In particular, Appellants argue on page 2 of the
reply brief that it is not obvious to modify Watkins to form a
function specifically prohibited by the system and that the
present invention is directed to parallel or multiprocessing
systems unlike that of Watkins.
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