Ex Parte Wilkinson et al - Page 6



          Appeal No. 2005-0133                                                        
          Application 10/037,390                                                      

          converter that converts the compiled form of an application into            
          a form suitable for interpretation by a specialized interpreter             
          that interprets derivative applications in the converted form.              
          Appellants assert that in Peyret the byte codes go directly from            
          compilation to interpretation without a conversion step.                    
          Appellants argue that the examiner’s reliance on Renner to meet             
          the conversion step is misplaced because the conversion in Renner           
          has nothing to do with converting the output of a compiler.                 
          Appellants assert, therefore, that there is no motivation in                
          Peyret or Renner to combine their respective teachings.  Even               
          though claim 106 does not recite an integrated circuit card,                
          appellants also argue that Peyret is silent on how to enable a              
          program written in a high level language to operate on an                   
          integrated circuit card [brief, pages 4-11].                                
          The examiner responds that a “specialized interpreter” is                   
          not claimed.  The examiner also responds that standard Java                 
          provides for the conversion feature when code is compiled on one            
          system and then transferred to another.  The examiner asserts               
          that Peyret teaches a reduced interpreter which suggests that               
          some type of converting occurs.  The examiner argues that both              
          Peyret and Renner teach the claimed conversion [answer, pages 3-            
          6].                                                                         
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