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Attorneys and agents who, without reflection, simply recycle old material in briefs basically treat the appeals process like filing a Request for Continued Examination (RCE) to enter a previously filed response; the client is paying for additional USPTO review of old material
from the top result below
https://ipwatchdog.com/2020/08/10/autopilot-advocate-raising-bar-ex-parte-appeals-uspto/
If an applicant still desires patent protection, it can authorize the filing of a notice of appeal to the Patent Trial and Appeal Board (PTAB) and an associated appeal brief
https://ipwatchdog.com/2014/05/24/obtaining-exclusive-rights-for-your-invention-in-the-united-states/
Obtaining Exclusive Rights for Your Invention in the United States - IPWatchdog