Appeal No. 2006-1605
Application No. 09/470,741
With respect to claims 1-7, 9, 11-12, 16-19, 21-24, 28-30
and 32-34, Appellants argue at pages 30 through 33 of the Appeal
Brief that the proposed combination of Vetro, Ng and Bose does
not teach the step of performing motion compensation for the
down-sampled image in the spatial domain, wherein the step of
performing the motion compensation includes the further step of
scaling a motion vector in accordance with a down sampling ratio,
and wherein the motion vector specifies the relative distance of
reference data from a macroblock, as required by the claimed
invention. Appellants also argue that there is no motivation to
combine the cited references since they teach starkly different
uses of motion vectors. Particularly, at page 30 of the Appeal
Brief, Appellants state the following:
Contrary to the Examiner’s assertions, the “motion
vectors” disclosed in Vetro et al. are vastly different
in purpose, effect, result and operation from the
“motion vectors” disclosed in Ng. (Vetro et al. Section
4.3, page 11, Bose et al., col. 17, lines 4-25, and Ng,
col. 4, lines 34-39). Also contrary to the Examiner’s
assertion, there is no motivation or suggestion in any
of the this (sic) prior art to selectively combine the
teachings of Vetro et al., Bose et al., and Ng in the
manner contemplated by the Examiner. Additionally,
given the stark differences between the “motion
vectors” disclosed in Vetro et al., Bose et al., and
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