Appeal No. 1997-1413
Application 07/765,757
it would have been obvious to design the output device to be
capable of recording data entered in a free-hand fashion based
on the non-alphanumeric characters exposed on film as taught
by Arifuku.
With respect to independent claims 1 and 18, appellant
argues that there is no motivation within the applied prior
art to have a photographic device with a writing pad as
claimed. Specifically, appellant argues that there is no
suggestion of a writing pad in Sakurada and Arifuku, and there
is no suggestion of using Johnston’s writing pad with a
photographic device. Appellant asserts that none of the
applied prior art suggests putting a handwritten sketch on
film and the examiner is guilty of hindsight reconstruction of
the invention [brief, pages 5-7]. The examiner responds that
the motivation for substituting Johnston’s writing pad for
Sakurada’s keyboard is to replace one kind of input device
with another, similar kind of input device having more
flexibility [answer, pages 13-16]. Appellant argues that the
characters suggested in Arifuku for exposure on a photographic
medium are not handwritten sketches as claimed, but rather,
are characters which have been prestored in a memory
9
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