Interference No. 104,693
Preputnick v, Provencher
37. According to Provencher, the first and
second contacts are defined by the configuration of the
overmolded plastic web formed about the contacts and
not by the provision of two different types of
contacts. This definition is contrary to the
understanding of one of ordinary skill in the art. An
ordinarily skilled artisan would understand ýfirst
contacts" and 'second contacts" by the configuration of
the contacts and not the overmolded plastic web that
surrounds the lead frame. An example of this common
understanding by those of ordinary skill in the art is
the Sasaki '770 patent, which discloses signal contact
blocks 11 and grounding contact blocks 12 that one of
ordinary skill in the art would consider half-modules,
inasmuch as the teaching of this patent is to combining
blocks 11 and 12 side by side to reduce cross-talk, and
the contacts of block 11 are clearly of a different
configuration from the second contacts of block 12.
Similarly, an ordinarily skilled artisan would
understand ýfirst lead frame" and 'second lead frame"
to denote a difference in shape or construction between
lead frames. (Preputnick Exhibit 2030, Sasaki '770
patent, col. 4, 11. 3-26, 40-59, Figs. 3C, 4-6C).
Mr. Granitz states his opinion in a conclusory manner, that
'[aln ordinary skilled artisan would understand 'first contacts'
and 'second contacts' by the configuration of the contacts and
not the overmolded plastic web that surrounds the lead frame."
The reference to U.S. Patent No. 5,174,770, as an example does
not support that conclusion. That there are first contacts which
are different in structure or configuration from second contacts
does not mean there can be no first contacts which are identical
in structure with second contacts. Mr. Granitz does not explain
why one with ordinary skill in the art would necessarily assume
that first contacts are different in structure and configuration
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