Ex Parte Sheynman et al - Page 5

                Appeal 2007-1415                                                                              
                Application 09/795,704                                                                        
                                                                                                             
                Rydbeck fails to disclose a router and operating mode switch coupled to the                   
                RF transceiver as claimed.  Appellants further argue that Rydbeck does not                    
                disclose an interoperability entity that is (1) coupled to the router and                     
                operating mode switch, and (2) coupled with the packet and circuit stacks as                  
                claimed.  In this regard, Appellants contend that controller 160 in Rydbeck                   
                is not an interoperability entity, but rather only (1) detects the presence of                
                modules 120, (2) identifies the protocol supported by each module, and (3)                    
                connects via switch 150 one module to man-machine interface 105 (Br. 5;                       
                Reply Br. 2).                                                                                 
                      The Examiner argues that because each communications module (i.e.,                      
                protocol stack) in Rydbeck contains functionality to facilitate                               
                communication between the mobile phone and a particular communication                         
                network, the stacks must be coupled to the RF transceiver in order to                         
                communicate at all (Answer 4).  The Examiner adds that Rydbeck’s                              
                controller 160 fully meets an “interoperability entity” as claimed since it                   
                “interoperates with the different network protocols” by selecting different                   
                protocols (Answer 5).                                                                         
                      Appellants also argue that the secondary reference, Mazur, teaches                      
                away from combining circuit and packet technologies.  According to                            
                Appellants, Mazur teaches implementing packet switched technology                             
                without circuit switched technology.  In particular, Appellants contend that                  
                Mazur introduces synchronization and frequency correction in a stand alone                    
                packet communications system without needing to implement a circuit                           
                switched system and its associated control channels (Br. 5).  Appellants also                 
                argue that Mazur is concerned with network architecture -- not handset                        
                architecture (Br. 5-6).                                                                       

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