Reply Brief in Support of KSR's Motion for Summary ... - Fried Frank

",U.S.S.N 09/236,975 2..,. .~-,!.,0_':PI"", conccl dmm 2.d-' '1. (An~nded) An apparatus as set fort in claim 1 wherein said pivot (24)Js(pivotaly mounted with respect to said vehicle strcture (20)) associate with said support.Q and said pedal ar (14) moves in fore and aft diections with respect to said pivot (24).cf¡sip. (New) A vehicle control pedal apparatus (12) comprising:a support (18) adpted to be mounted to a vehicle strctue (20);an adjustable pedal assembly (22)and aft diections with respect to said support (18);having a peda ar (14) moveable in forea pivot (24) for pivotaly supportng said adjustable peda assembly (22)with respect to said support (18) and defig a pivot axis (26); andan electronic thottle control (28) attached to said support (18) forcontrollng an engine thotte (30);said apparatus (12) chàràcterized by said electronic throttle control (28)being responsive to said pivot (24) for providing a signal (32) that corresponds to pedal arposition as said peda ar (14) pivots about said pivot axs (26) between rest and appliedIPOSitiO~ wherein the p~Siti~n of S~d pivot (24) r~~s constant while said pedal ar (14)\,moves il fore and af directions with repect to said pivot (24).IS'I lp yf. (New) An appartu as set fort in clai y5 wherein said electronic thotte17control (28) is fixed relative to said vehicleI~strctue (20) such that said peda ar (14)moves in fore and af diections with respect to said electroiuc thotte control (28). .0. (New) An apparat as set fort in clai vf wherein said adjustable pedadefines aassembly includes a gude rod (62) for supportg said pedal ar (14) and whichlongitudinal axs (64), said peda ar (14) moving in said fore and af diecons along saidlongitudial axs (64)..,dì ..\. ,.