Remarks from page 5 in support of claim 5 of “737” patent

Combination of Kimura and Toru is not operative or does not result in the subject matter of claim 5. Specifically , Toru teaches that NVM are not removable.

The purpose of the first test, which tests identification number matching, is to determine whether the NVM is in fact inserted in the correct location. Thus Toru teaches NVMs that are secured to a substrate in a fixed location and that are not removable.

Toru discloses an NVM that is inserted to a fixed location on a substrate before power on.

Kimura discloses a recorder that uses a removable NVM. An attempt to use the Toru NVM which is secured in a fixed location, in place of the removable Kimura would be inoperative .

NVM = Non Volatile Memory