[00:00:08] Speaker 04:
The next case for argument is 181697, Bridge and Post versus Verizon.

[00:01:00] Speaker 05:
We're ready, Mr. Johnson, whenever you are.

[00:01:09] Speaker 04:
Good morning.

[00:01:13] Speaker 01:
We're here on appeal from a decision by the trial court where we were never even allowed an opportunity for an argument, where the trial court entered an order.

[00:01:27] Speaker 01:
we believe is directly contrary not only to what was patented, but also to the allegations set forth in the complaint and in the specification.

[00:01:39] Speaker 01:
By way of example, the trial court in his order said that our technology had hijacked consumer privacy.

[00:01:53] Speaker 00:
Well, that's just a flowery introduction to an opinion.

[00:01:59] Speaker 00:
But he actually got into the issues and the patents.

[00:02:03] Speaker 01:
He did in part, Your Honor, but he did not in fact.

[00:02:08] Speaker 01:
And I can explain that.

[00:02:10] Speaker 01:
He said, for example, that the technology was an abstract idea.

[00:02:19] Speaker 01:
He then said that that quote abstract idea was simply related to the delivery of targeted content.

[00:02:31] Speaker 01:
Unfortunately, he didn't bother to look at the claims to find out how that was done.

[00:02:38] Speaker 01:
For example, he admitted in his order that there was prior art technology out there, like cookies.

[00:02:48] Speaker 01:
like IP addresses that had been used to deliver targeted content in the past.

[00:02:55] Speaker 01:
He admitted that our approach was an approach that was different and that was designed to overcome the problems with targeted material from cookies.

[00:03:08] Speaker 01:
And by way of an example, let me just explain.

[00:03:13] Speaker 01:
The older approach, and I'm going to go before cookies, where you just had bricks and mortar, you delivered your content either by way of a newspaper, a commercial, and it was generalized.

[00:03:32] Speaker 01:
That evolved into being able to deliver content to someone's zip code.

[00:03:39] Speaker 01:
Again, that was an approach that was discussed.

[00:03:43] Speaker 01:
After the internet came into being, cookies were employed.

[00:03:48] Speaker 01:
And cookies were significant because cookies attached to the user's device.

[00:03:55] Speaker 01:
And it was a point to point.

[00:03:56] Speaker 01:
That is to say, it went from the user's device to the particular website that was being accessed.

[00:04:03] Speaker 01:
And the problem with cookies was you were able to get all sorts of personal information stored and collected.

[00:04:11] Speaker 01:
which would invade the user's privacy rights.

[00:04:16] Speaker 01:
The internet, as we know, is worldwide.

[00:04:21] Speaker 01:
And because of that, if you were delivering targeted marketing.

[00:04:25] Speaker 00:
The problem is claims like these pass information back and forth, which has been held to be abstract, an abstraction, and therefore not patent eligible.

[00:04:39] Speaker 00:
And cookies.

[00:04:43] Speaker 00:
are involved in the same process.

[00:04:45] Speaker 01:
Right.

[00:04:46] Speaker 01:
The difference is this is much more than merely passing information.

[00:04:51] Speaker 01:
The user directs a request to a website and we're talking now about the 594.

[00:05:01] Speaker 01:
That information or that direction is intercepted and a persistent identifier is created.

[00:05:08] Speaker 01:
So you know what that device is and where it is at all times.

[00:05:13] Speaker 01:
That is significant because if I'm in Washington DC today and New York City tomorrow, my persistent identifier will indicate to the content provider where I am.

[00:05:26] Speaker 01:
That is not true.

[00:05:27] Speaker 00:
But even if that's a clever idea, adding an abstraction to an abstraction doesn't change the fact of abstraction, does it?

[00:05:35] Speaker 01:
Well, if you say, I'm adding an abstraction to an abstraction, that assumes that there was no device involved.

[00:05:43] Speaker 01:
And that assumes that those devices were not operating in a way to enable you to accomplish what you planned to.

[00:05:50] Speaker 01:
But if you look at the 594,

[00:05:53] Speaker 01:
And you look specifically at, say, figure two, you will see on the left side you have access devices.

[00:06:01] Speaker 01:
On the right side you have very specific devices that are required.

[00:06:08] Speaker 01:
For example, there is a CR server.

[00:06:12] Speaker 01:
Consumer Relationship Server.

[00:06:13] Speaker 01:
That Consumer Relationship Server has to be there, and it has to do certain specific things.

[00:06:20] Speaker 01:
If those things aren't done, you simply are not practicing the path.

[00:06:25] Speaker 01:
Now, we know further.

[00:06:27] Speaker 05:
But what is the relevance of what you're saying?

[00:06:31] Speaker 05:
I mean, that there's a device that's, if a device is just a generic device.

[00:06:35] Speaker 05:
No, it's not a generic device.

[00:06:37] Speaker 05:
I don't understand the significance of your saying.

[00:06:42] Speaker 01:
So if you have a persistent device identifier, you still need to develop a consumer profile.

[00:06:49] Speaker 01:
That consumer profile is developed in the CR server.

[00:06:53] Speaker 01:
But in addition to that, you also have information about location and time that also has to be developed.

[00:07:03] Speaker 01:
So for example, if you are at Starbucks,

[00:07:07] Speaker 01:
and you go through an access point, you are able, at that point, using this technology, to recognize that you are at Starbucks in Washington DC at a certain time, and that perhaps next door there is a store that you might otherwise frequent based upon your user or group identifier.

[00:07:29] Speaker 05:
Well, as Judge Lloyd pointed, I mean, by this time, we've got quite a bit of case law in this area, and a lot of it

[00:07:36] Speaker 05:
sounds familiar in terms of these devices and exchanging information and so forth.

[00:07:41] Speaker 05:
So what's your case?

[00:07:44] Speaker 01:
Well, our case is very much like Incora.

[00:07:49] Speaker 01:
In Incora, you were dealing with another solution to deal with hacking.

[00:07:55] Speaker 01:
And the solution they came up with was to modify the bios, tag it,

[00:08:02] Speaker 01:
to prevent ease of access by hackers.

[00:08:07] Speaker 01:
And in our case, we developed an approach where you use the HTTP tag, and you are able to provide information.

[00:08:19] Speaker 01:
The information, remember, these tags are primarily for routing.

[00:08:23] Speaker 01:
But the tag takes the information, provides it to

[00:08:28] Speaker 01:
to the target identifier, and that target identifier can then decode it and provide a specific targeted marketing information to you.

[00:08:54] Speaker 00:
All in the same way, if we accept your argument, they all pass, and if we don't, none of them do?

[00:09:02] Speaker 01:
Each one stand on its own.

[00:09:04] Speaker 00:
Yes.

[00:09:05] Speaker 00:
That's correct.

[00:09:05] Speaker 00:
In fact, in law, but in terms of the concepts.

[00:09:08] Speaker 01:
No, the concepts are different.

[00:09:10] Speaker 01:
So for example, 594, let's use the example of myself.

[00:09:14] Speaker 01:
So with the 594, I go out to the web.

[00:09:18] Speaker 01:
My persistent identifier, which is the phone, is then identified

[00:09:24] Speaker 01:
Personalized information is extracted and located in the CR server that information is then available for use by someone involved in in direct marketing that information once it's developed enables them to know where I am What I'm doing and it also enables them to provide targeted the targeted information that had never been done before Now if we go to the next one which is

[00:09:55] Speaker 01:
747, that is a different technique.

[00:09:59] Speaker 01:
It talks about how you develop tags that would be useful for implementing this particular scheme.

[00:10:09] Speaker 01:
And in fact, what happens is you get location information, time information, et cetera.

[00:10:15] Speaker 01:
You have it stored in a location where it can be encrypted

[00:10:21] Speaker 01:
provided to a media outlet.

[00:10:26] Speaker 01:
And if they choose, they can then target you.

[00:10:29] Speaker 01:
But you have to have this tagging information in order to accomplish that.

[00:10:34] Speaker 03:
But the 747 is the only one of the three patents that actually claims, as I understand it, the inclusion of this information in the HTTP header.

[00:10:44] Speaker 03:
Correct yeah, so that that that is a degree of specificity It seems to me that for example the 594 patent lacks I don't see anything Comparable to that in the 594 if you if you will go to go to claim 15 claim 15 in the 594 is a system path system claim excuse me and it provides a

[00:11:14] Speaker 01:
Sufficient detail and it talks about providing the You get the demographic information is provided to the server computer in the form of user profile data And the location is provided to the server computer in the form of data selected from the group consisting of zip codes And then you have international codes etc.

[00:11:36] Speaker 03:
Right, but that's all

[00:11:37] Speaker 03:
It all has a very functional feel to it.

[00:11:40] Speaker 03:
It's describing a function without describing the specific mechanics of performing the function.

[00:11:49] Speaker 01:
But the specific mechanics are detailed.

[00:11:52] Speaker 03:
But they're detailed in the specification, perhaps, but they don't find their way into the claims.

[00:11:57] Speaker 01:
But let's go back to claim one.

[00:11:59] Speaker 01:
All right.

[00:12:00] Speaker 01:
So claim one says,

[00:12:13] Speaker 00:
Certainly doesn't refer to HTTP.

[00:12:16] Speaker 01:
I'm sorry?

[00:12:17] Speaker 00:
Certainly doesn't refer to HTTP.

[00:12:19] Speaker 01:
No, you don't have HTTP there.

[00:12:21] Speaker 01:
What you have is you retrieve your persistent identifier.

[00:12:24] Speaker 01:
Then you have to determine the network address and then one or more characteristics.

[00:12:31] Speaker 01:
And then you have to retrieve historic information that's also on the internet.

[00:12:37] Speaker 01:
And then you have to use that information to determine how many times and locations

[00:12:42] Speaker 01:
the particular persistent identifier is in use.

[00:12:46] Speaker 01:
And then once that's done, then you generate the user profile based upon the historic information.

[00:12:51] Speaker 01:
And then you store the user profile as a record that then identifies the user.

[00:12:58] Speaker 01:
Then you incorporate that into the user profile.

[00:13:00] Speaker 01:
And then once that's done, then you assign a group identifier.

[00:13:04] Speaker 01:
And after you've done that, the result is you then analyze and retrieve the device identifier

[00:13:10] Speaker 01:
the historical information, and once you've done that, then you place the directed media, by the directed media component, to a particular website.

[00:13:20] Speaker 00:
Those are all specific.

[00:13:22] Speaker 00:
It's all software, right?

[00:13:23] Speaker 01:
No, it's hardware, software and hardware.

[00:13:27] Speaker 01:
You cannot do it unless you have the CR server.

[00:13:30] Speaker 00:
It's known hardware plus software.

[00:13:33] Speaker 01:
But it's known hardware used in a different way.

[00:13:36] Speaker 01:
No one has ever done that before.

[00:13:38] Speaker 00:
And that's why you are able... Is that a question of obviousness, novelty?

[00:13:44] Speaker 00:
Not 101.

[00:13:44] Speaker 01:
No, that would not be 101.

[00:13:48] Speaker 01:
But in the answer to your question, no, I don't believe it would be obvious.

[00:13:51] Speaker 00:
And the reason is because of the ultimate... No, but I mean, isn't it an obviousness question?

[00:13:57] Speaker 00:
Which isn't before us before us is patent eligibility, right?

[00:14:02] Speaker 01:
Yes abstraction, right if you say that this is an improvement over the use of prior art systems like cookies Then we aren't talking about an abstraction you come clearly within claim one of ounce and if you're saying that

[00:14:19] Speaker 01:
Well, we need to know more specifics.

[00:14:23] Speaker 01:
We have provided you specific detail here in Claim 1.

[00:14:26] Speaker 01:
And you know, I apologize.

[00:14:27] Speaker 01:
I read Claim 15 from the different patent.

[00:14:31] Speaker 01:
If you look at Claim 15 in the 594, you'll see.

[00:14:34] Speaker 01:
I was reading 15 from the 594.

[00:14:39] Speaker 01:
I'm not going to grab my hand.

[00:14:40] Speaker 01:
Put my hands on it.

[00:14:43] Speaker 03:
It's on Appendix 64.

[00:14:56] Speaker 01:
Yeah, if you look at Claim 15, Column 13 and Appendix 64, that is not an abstraction.

[00:15:03] Speaker 01:
That provides detailed components about how you are to accomplish the result.

[00:15:11] Speaker 05:
Okay, we've, you're into your rebuttal time, so why don't you?

[00:15:24] Speaker 04:
Thank you.

[00:15:24] Speaker 04:
Good morning.

[00:15:25] Speaker 02:
May I please the court?

[00:15:26] Speaker 02:
Deanne Maynard on behalf of Verizon.

[00:15:30] Speaker 02:
The patents at issue here take business practices that this court already has held to be abstract and implement them with generic technology used in conventional ways.

[00:15:43] Speaker 03:
I understand your argument with respect to the 594 and the 314.

[00:15:49] Speaker 03:
I think it's 314.

[00:15:50] Speaker 02:
Yes, sir.

[00:15:51] Speaker 03:
I'm having more trouble with your argument as applied to the 747, because there, and that's the one that has the HTTP header, and the RID gets encrypted and put into it.

[00:16:03] Speaker 03:
That sounds specific to me.

[00:16:05] Speaker 03:
That sounds like something that gets far beyond the generic functional sounding language that's used in the claims asserted from the other patents.

[00:16:15] Speaker 02:
OK.

[00:16:16] Speaker 02:
So one, Your Honor is correct that the 747 is the only one that has the issue that you're raising.

[00:16:21] Speaker 02:
But I don't think it changes the analysis, and here's why, for a number of reasons.

[00:16:26] Speaker 02:
One, the 747 is still directed to an abstract idea of transmitting user information using encrypted.

[00:16:37] Speaker 03:
But even if that's true, isn't it doing it in a very specific way?

[00:16:42] Speaker 03:
Isn't it saying, we could do this in any number of ways?

[00:16:46] Speaker 03:
And the other claims.

[00:16:47] Speaker 03:
don't limit the ways they can be done.

[00:16:49] Speaker 03:
But we here are doing it by taking the information, encrypting it, and sticking it in a place where it's, at least by hypothesis, never been put before.

[00:17:00] Speaker 02:
OK, two points about that.

[00:17:02] Speaker 02:
One, obviously, specificity is not enough to get you eligibility.

[00:17:05] Speaker 02:
This court's held that.

[00:17:06] Speaker 02:
Nor is limiting an abstract idea to a particular technology.

[00:17:10] Speaker 02:
And then, perhaps more importantly to your honor's question, the specification makes clear

[00:17:15] Speaker 02:
That is a conventional use of the HTTP header.

[00:17:18] Speaker 02:
Specification makes clear that HTTP headers already contain user information, and they're just putting additional user information into blank space.

[00:17:30] Speaker 02:
If this were secured mail, and secured mail just taking the barcode and putting it in a blank space on the envelope, this is just taking that same abstract idea and putting it in a blank space in the HTTP header that's already

[00:17:43] Speaker 02:
used in that very way.

[00:17:45] Speaker 02:
And I can point, Your Honor, to the place in the specification where it talks about just the standard use of the HTTP header.

[00:17:50] Speaker 02:
So looking at, so which pattern would you prefer, the 3 and 4 or the 7 and 4 and 7?

[00:18:04] Speaker 02:
Either one.

[00:18:04] Speaker 02:
So at the 7 and 4 and 6, appendix 80, column 9, lines 2 to 5.

[00:18:11] Speaker 02:
It talks about standard HTTP requests include various content fields, including headers and data fields which accommodate incremental information from the networks.

[00:18:19] Speaker 02:
The HTTP header is already used to add information.

[00:18:22] Speaker 02:
This is not changing it in kind.

[00:18:25] Speaker 03:
But isn't that an advantage of the patent?

[00:18:28] Speaker 03:
In other words, what the patents, the cleverness here, if there is, is that we've taken the technology that's already out there.

[00:18:36] Speaker 03:
We don't have to make any big changes.

[00:18:38] Speaker 03:
But we're exploiting a feature that hasn't

[00:18:41] Speaker 03:
again, by hypothesis, been exploited before and doing something that hasn't been done before by using already existing technology, the HTTP header.

[00:18:53] Speaker 02:
But implementing the abstract idea, which is the tagging.

[00:18:56] Speaker 02:
Tagging is the abstract idea, recognized and secured mail.

[00:18:59] Speaker 02:
Tagging and encrypting information about the sender is just an abstract idea.

[00:19:03] Speaker 02:
And this is just implementing that abstract idea on generic technology, can be any kind of header,

[00:19:11] Speaker 02:
any kind of HTTP header in a conventional way, Judge Bryson.

[00:19:15] Speaker 02:
The way that the specification makes clear, HTTP headers already contain information about the user, like the user's browser.

[00:19:21] Speaker 02:
And it already contains blank fields.

[00:19:26] Speaker 02:
If you look at APPX, this is like with column 9, 40 to 42.

[00:19:30] Speaker 02:
The HTTP header also includes one or more extensible fields that are essentially blank, but can be used to store additional data.

[00:19:37] Speaker 02:
So it's unlike ANCORA.

[00:19:39] Speaker 02:
So he points to ANCORA, which came out after our red brief.

[00:19:42] Speaker 02:
We address it in our Rule 28j letter.

[00:19:44] Speaker 02:
But ANCORA is different, because ANCORA is using the BIOS in a way that the BIOS has never been used before to improve the functioning of the computer itself.

[00:19:54] Speaker 02:
So those are two distinct differences between what's going on here with the HTTP header, which the specification makes clear is just an ordinary conventional use of the HTTP header, which is to put information about the user in it.

[00:20:07] Speaker 02:
and transmit it along with the traffic like the rest of the information that's already in the header to go along as a tag just to implement the abstract idea from secured mail.

[00:20:17] Speaker 02:
And Quora uses the bios in a way that the bios has, the court concluded, not been used before to include information unlike of a different kind than the bios has ever been used before.

[00:20:28] Speaker 02:
This is the same kind.

[00:20:29] Speaker 02:
This is using the HTTP header to carry the same kind of information, the HTTP header.

[00:20:34] Speaker 02:
already is used to carry.

[00:20:36] Speaker 02:
It's not coming up with any new way, unconventional way of doing it.

[00:20:41] Speaker 02:
It's just implementing the abstract idea using conventional technology.

[00:20:46] Speaker 02:
It's like, take secured mail and do it on internet traffic.

[00:20:51] Speaker 02:
That's it.

[00:20:52] Speaker 02:
So even if it is a new, clever place and it hasn't been put there before, a new, clever idea isn't enough to get you out of abstract ineligibility if all you're doing is implementing the abstract idea, which tagging is.

[00:21:04] Speaker 02:
If it's new and clever, it probably isn't conventional routine and well-known.

[00:21:11] Speaker 02:
No, I think there's a difference between the two, Your Honor.

[00:21:14] Speaker 02:
One is it's a new idea to tag the information

[00:21:18] Speaker 02:
Secured mail could have been a new idea.

[00:21:21] Speaker 02:
Putting the barcodes and all that could be a new idea, could be beneficial in some way.

[00:21:24] Speaker 02:
But it doesn't make the use of those things unconventional.

[00:21:28] Speaker 02:
And the specification makes clear that the same kind of information is already carried in the HTTP header, and they're just adding new information to it.

[00:21:38] Speaker 02:
So new information of the same kind.

[00:21:41] Speaker 03:
Would your answer be different if, in fact, no one had actually put this kind of information in an HTTP header before?

[00:21:50] Speaker 03:
It was sitting there.

[00:21:52] Speaker 03:
unused, and this patent says, we've got a use for it.

[00:21:57] Speaker 03:
Stick it in.

[00:21:58] Speaker 02:
Would that render it no longer an abstract idea?

[00:22:03] Speaker 02:
I don't know, Your Honor, because I still go back to secured mail.

[00:22:05] Speaker 02:
And if you say, if the claims in secured mail had said, well, and stick the barcode on a blank spot on the envelope, would you have thought that that took it out of from ineligibility to eligibility?

[00:22:15] Speaker 02:
I don't think so.

[00:22:16] Speaker 02:
And this is no different than that, empty space in the HTTP header.

[00:22:20] Speaker 02:
But I do think it does help us.

[00:22:22] Speaker 02:
that the specification makes clear that it already carries information about the user's browser in it, including information about the user is already flowing with the traffic.

[00:22:35] Speaker 02:
And so they make an idea that they intercept, and they make assertions that somehow they're rerouting the traffic, but they're not rerouting the traffic.

[00:22:42] Speaker 02:
The traffic is going the same way it always goes, from the user's request on conventional technology through a conventional router.

[00:22:50] Speaker 02:
And that's another thing.

[00:22:51] Speaker 02:
It can be any router.

[00:22:53] Speaker 02:
It's through the router to the content provider.

[00:22:55] Speaker 02:
The traffic just goes right through that.

[00:22:57] Speaker 02:
And the HTTP headers is traveling with that in the ordinary way.

[00:23:01] Speaker 02:
And they've just proposed adding additional information to that header of the same ilk that's already there.

[00:23:07] Speaker 02:
And that is just implementing the abstract idea on generic technology in a conventional way, which is not enough to make it patent eligible.

[00:23:21] Speaker 02:
I mean, I'm happy to answer.

[00:23:22] Speaker 02:
Additional questions about that, or you still look unsatisfied?

[00:23:27] Speaker 02:
I can point you to the specification.

[00:23:28] Speaker 02:
I didn't mean to give any indication of lack of satisfaction.

[00:23:33] Speaker 02:
I appreciate your answer.

[00:23:35] Speaker 02:
Would your honors like me to address any questions about the other?

[00:23:39] Speaker 02:
The 594 patent is just targeted marketing.

[00:23:45] Speaker 02:
And this court already held the same concepts to be abstract and intellectual ventures.

[00:23:50] Speaker 02:
And as Judge Laurie pointed out, adding the additional abstract idea that use a persistent identifier, which is a known thing, to that doesn't change it.

[00:23:58] Speaker 03:
And you see the 314 is falling into the same category.

[00:24:01] Speaker 02:
The 314 is, I think, the abstract idea from secured mail.

[00:24:05] Speaker 02:
And so all of the things that I said about the 747 patent apply to the 314, except it doesn't, as your honor recognized, even claim the tagging into the HTTP header.

[00:24:17] Speaker 02:
So the 314 is just like secured mail.

[00:24:23] Speaker 02:
It's like the internet request goes.

[00:24:26] Speaker 02:
You tag user information onto the request.

[00:24:29] Speaker 02:
and you encrypt it, the technology can be any off-the-shelf, standard off-the-shelf components, any technology used to send.

[00:24:39] Speaker 02:
There's nothing special about the ID.

[00:24:43] Speaker 02:
It can be any ID, including a MAC ID.

[00:24:45] Speaker 02:
The fact that they propose to take, in some claims, to take different IDs and add them together, that idea was in Secured Mail 2.

[00:24:53] Speaker 02:
There's nothing

[00:24:55] Speaker 02:
to take it out of the abstract world and there's nothing unconventional about it the way that they've implemented it in either I think the 314 or the 747 patents.

[00:25:07] Speaker 02:
So basically the whole discussion I have with you about they're not changing the way the traffic goes.

[00:25:14] Speaker 02:
It goes in the same exact way.

[00:25:17] Speaker 02:
It just really takes secured mail and taking

[00:25:21] Speaker 02:
encrypt some information about the sender and have it flow along with the mail.

[00:25:26] Speaker 03:
So you see the 594 and the 314 as a first priority from the 747?

[00:25:32] Speaker 02:
Yes, if you agree with us, the 747.

[00:25:38] Speaker 02:
But I think that I would separate them differently than that.

[00:25:42] Speaker 02:
So I think that the abstract idea in the 594 patent is the abstract idea from Intellectual Ventures.

[00:25:50] Speaker 02:
It's directed marketing.

[00:25:52] Speaker 02:
It's like collecting user makes a request.

[00:25:54] Speaker 02:
Which of the intellectual ventures is it?

[00:25:56] Speaker 02:
The one in 792.

[00:25:57] Speaker 02:
The one in 792.

[00:25:58] Speaker 02:
Okay.

[00:25:59] Speaker 02:
So it's not the XML one, but the one about putting up website content in reaction to who the user is.

[00:26:08] Speaker 02:
I mean just gathering and collecting information about the user and then serving up targeted ads to them.

[00:26:13] Speaker 02:
There's nothing claimed special there.

[00:26:16] Speaker 02:
They don't claim to have invented any of the technology.

[00:26:18] Speaker 02:
They don't claim to have invented any of the technology in any of these patents.

[00:26:22] Speaker 02:
And then so then I would say that's on that.

[00:26:24] Speaker 02:
And then the 314 and the 747 patent, they are the abstract idea from secured mail, which is just taking information about the sender, encrypting some information into it, and then sending information in response to that, and that they implement that with

[00:26:43] Speaker 02:
generic technology in conventional ways.

[00:26:47] Speaker 02:
And then, you know, we've already had the discussion about why I think that using HTTP headers is just a conventional use of the HTTP header.

[00:26:53] Speaker 02:
And narrowing it down to a specific detail like that doesn't save it from being abstract.

[00:26:59] Speaker 02:
We would request that you affirm.

[00:27:01] Speaker 01:
Thank you.

[00:27:07] Speaker 01:
Let's start again with the 594, which if counsel is to

[00:27:11] Speaker 01:
Council says is not at all Unique and the reality is it is in fact unique.

[00:27:19] Speaker 01:
It is the first time where you are able to create a profile From the network not from the device.

[00:27:30] Speaker 01:
This is all on the network side The reason that's important.

[00:27:35] Speaker 01:
It's twofold one anonymity to privacy

[00:27:40] Speaker 01:
So this is all being done on the network side, and it does not include personal information, which again is an improvement over what had been done before.

[00:27:50] Speaker 01:
And since it can only be created by the network, the user is not involved in that process.

[00:27:59] Speaker 01:
And using the identifier for that approach creates the system that we believe is unique.

[00:28:07] Speaker 01:
You heard counsel say that this is just like using a stamp in an envelope.

[00:28:14] Speaker 01:
It is not.

[00:28:16] Speaker 01:
A barcode.

[00:28:17] Speaker 01:
It's not.

[00:28:17] Speaker 01:
Because you can't use a barcode on the internet.

[00:28:21] Speaker 01:
You have to be able to track some device in order to be able to identify what it is you want to target for that individual.

[00:28:32] Speaker 01:
That simply cannot be done in a conventional way.

[00:28:35] Speaker 01:
What was done here was unique because you can track the individual device, the individual device holder, wherever that person is, using whatever access point.

[00:28:48] Speaker 01:
Now, you asked the question in the outset about, is this just software?

[00:28:52] Speaker 01:
I said, no, it's hardware and software.

[00:28:54] Speaker 01:
But this is no different than what happened in DDR.

[00:28:57] Speaker 01:
It's no different.

[00:28:58] Speaker 01:
This is a solution that allows you to market in ways that could never be done before.

[00:29:05] Speaker 01:
It's easy to say oh everybody knows marketing well that may be true, but you cannot market on the internet One-to-one if you want to find out what a person is doing everywhere.

[00:29:20] Speaker 04:
They go to the capital Thank you