[00:00:32] Speaker 01:
Our next case is Corning Optical Communications versus Pandoit, 2019, 1248 and 1250, Mr. O'Quinn.

[00:00:52] Speaker 02:
Before you start, can I just tell you how much I appreciate that you limited your arguments on appeal to what you thought were the most successful arguments and didn't raise every single issue from the IPRs, because that rarely happens.

[00:01:06] Speaker 02:
And I really appreciate appellate counsel selectively making their arguments and not throwing the kitchen sink at us.

[00:01:15] Speaker 04:
Well, thank you, Judge Hughes.

[00:01:16] Speaker 04:
I appreciate that.

[00:01:17] Speaker 04:
And thank you, Judge Lawrie.

[00:01:18] Speaker 04:
You may have pleased the court.

[00:01:19] Speaker 04:
John Aucoin on behalf of Corning.

[00:01:21] Speaker 04:
We have focused on a singular issue on appeal, because it's one where Pandewitt's obviousness arguments depend on taking the claimed invention and working backwards to conclude that it would be obvious to make and use the first ever translucent cam mechanism.

[00:01:39] Speaker 04:
But the very prior art that Pandewitt relies on, the Takazawa reference, teaches a different solution to the purported problem.

[00:01:48] Speaker 04:
The claims require, and this is why we appeal just with respect to these claims, Judge Hughes, the claims require both a translucent splice component and a translucent cam.

[00:01:58] Speaker 04:
But Takazawa only teaches the former and not the latter, and it is undisputed

[00:02:04] Speaker 04:
that there was no translucent cam disclosed anywhere in the prior art.

[00:02:09] Speaker 04:
Yet you will search Pandowitz expert's testimony and the board's decision in vain to find any analysis or any reasoning for why a skilled artisan with Takazawa in hand would have been motivated to develop a translucent cam rather than using Takazawa's solution of a forcing mechanism with a physical opening.

[00:02:32] Speaker 04:
That's a solution that Takazawa itself put emphasis on.

[00:02:36] Speaker 04:
If you look at appendix 1144, column 8, lines 49 to 53, Takazawa tells you that the clamping force applying device 36 is not limited to a C-shaped spring, provided that an opening 48 can be obtained.

[00:02:55] Speaker 04:
Yet neither Pandowitz expert nor the board identify any drawbacks to Takazawa's solution.

[00:03:00] Speaker 04:
Instead, they argue at page 34 of their red brief that their expert was not even required to consider Takazawa's solution because they relied on different prior art for the disclosure of a CAM.

[00:03:14] Speaker 04:
Now, respectfully, that doesn't make sense.

[00:03:17] Speaker 04:
When you're assessing motivation, this court has made clear in cases like Polaris versus Arcticat

[00:03:25] Speaker 04:
and Arendy versus Appel, there must be some reason for not pursuing a known solution to the purported problem, or some reason for not pursuing a divergent path.

[00:03:37] Speaker 04:
And this court in Polaris versus Arcticac was very clear that the board must analyze whether a skilled artisan would be led in a direction that diverges from the path that was taken by the patentee.

[00:03:50] Speaker 04:
Here in this case, in light of Takazawa's other

[00:03:53] Speaker 02:
But isn't the reason here that the clamp in Takazawa is not removable once you put it on, and your cam is, and isn't that enough of a reason to say, well we're going to move from this clamp to the

[00:04:17] Speaker 02:
to the cam, and because we need to see into it, instead of having the gap, we're going to use a translucent cam.

[00:04:26] Speaker 02:
I mean, that seems to be a reason to do it.

[00:04:28] Speaker 02:
I don't know that that was articulated well enough.

[00:04:32] Speaker 02:
Although this is, you know, you're on a very hard center of view here.

[00:04:35] Speaker 02:
And they do have some expert testimony suggesting that it would make sense.

[00:04:39] Speaker 02:
So I guess, isn't that enough of a reason to go from Takazawa to a translucent cam?

[00:04:47] Speaker 04:
So Judge Hughes, first, I'm not sure at all that the C-shaped spring, once it's applied, is not removable.

[00:04:54] Speaker 04:
I'm not aware of that being the case.

[00:04:58] Speaker 02:
Maybe I misread the record, but let's just assume that was true.

[00:05:01] Speaker 02:
That would seem to me to be the sense I got.

[00:05:03] Speaker 02:
That was one of the doubts.

[00:05:05] Speaker 02:
And maybe your friends can correct me if I'm wrong.

[00:05:08] Speaker 02:
But let's assume that's true.

[00:05:10] Speaker 02:
Isn't that a reason, enough of a reason to modify the whole splicing technique in Takazawa with a translucent cam instead of this, you know, gapped C-clamp?

[00:05:21] Speaker 04:
So Judge Hughes, there might be reasons to say that you would prefer using the type of mechanical cam device that we used as opposed to the spring device that Takazawa used, but you won't find any analysis for why the person of ordinary skill in the art would be led to, with Takazawa in hand,

[00:05:45] Speaker 04:
to use the CAM and to make the CAM translucent.

[00:05:48] Speaker 04:
There's literally nothing in their expert's analysis to say, oh, well, a person of ordinary skill in the art would recognize that this solution would be better.

[00:05:59] Speaker 04:
And that's exactly what I'm saying is missing here, that there needs to be some analysis

[00:06:04] Speaker 04:
for why a person of ordinary skill in the art would think that this combination was better than a combination that uses Takazawa's teachings.

[00:06:14] Speaker 04:
And that doesn't mean that somebody has to mechanically take Takazawa's spring and apply... Why do they have to say it would have been better?

[00:06:21] Speaker 02:
Can't they just say, looking at the prior art, a skilled artisan would have known to do this?

[00:06:26] Speaker 02:
Not that it's better, but that it

[00:06:28] Speaker 02:
could be done.

[00:06:29] Speaker 02:
And isn't that what their experts said?

[00:06:31] Speaker 02:
I mean, I struggle with this.

[00:06:34] Speaker 02:
This seems a little hindsight-y to me.

[00:06:36] Speaker 02:
I know that's not real work.

[00:06:39] Speaker 02:
But again, I'm on a really hard standard of review here.

[00:06:42] Speaker 02:
And it seems like Takazawa has pretty much everything except the, well, and all the other references.

[00:06:49] Speaker 02:
But none of those are really in dispute.

[00:06:51] Speaker 02:
except the translucent cam, and there's at least some testimony from their expert suggesting why that a skilled artisan would know to use this.

[00:07:01] Speaker 04:
Well, Judge Hughes, a couple of things.

[00:07:03] Speaker 04:
First, I think what's fundamentally going on here is that Pandewitt's approach offers a solution in search of a problem that didn't need solving.

[00:07:12] Speaker 04:
That is, Takazawa provides a complete solution for how to be able to

[00:07:16] Speaker 04:
to see the light, if that is the motivation that they want to rely on for why somebody would have combined all of these things together in the first place.

[00:07:25] Speaker 04:
And second, while I agree with you that, yes, the standard of review is an important one here, number one, I think that what the board has done has engaged in legal error.

[00:07:38] Speaker 04:
Because the board never grapples with the argument that I'm making.

[00:07:42] Speaker 04:
The board doesn't say,

[00:07:44] Speaker 04:
Hey, you're right.

[00:07:45] Speaker 04:
There's a reason that a person would still be motivated by this, even though Takazawa teaches a complete solution.

[00:07:51] Speaker 04:
Instead, at pages 25 and 28, the board just simply says, Pandoit, quote, relies on de Jong and CAM light and not Takazawa for teaching the recited CAM mechanism, end quote.

[00:08:03] Speaker 04:
That's a legal error in the board's analysis.

[00:08:06] Speaker 04:
And to the extent that you're positing, well, maybe there would be a reason that a person of ordinary skill in the art

[00:08:12] Speaker 04:
that it would make sense to modify in light of what they've learned from Takazawa, what you're now doing is positing things that are not in the record.

[00:08:23] Speaker 04:
And we're, of course, here on APA review.

[00:08:25] Speaker 04:
The court cannot affirm on

[00:08:28] Speaker 04:
alternative grounds or alternative hypotheticals that it can only affirm on things that are in the record.

[00:08:34] Speaker 04:
And the record does not reflect a reason that a person of ordinary skill in the art would take the teachings of Takizawa and say, oh, well, that means that I should not only have the translucent splicing components,

[00:08:48] Speaker 04:
But even though Takazawa teaches using a physical opening, and you could do the same with a cam, you could have a physical opening in the cam, instead of doing what Takazawa teaches, I'm going to instead say, let's have a translucent cam for the first time ever.

[00:09:04] Speaker 04:
And the only thing that they even attempt to point to, and the only thing that the board quotes, is there's a passage from their expert that talks about

[00:09:14] Speaker 04:
that you could potentially quote view from a variety of directions rather than only one specific viewing direction.

[00:09:21] Speaker 04:
That's appendix 1027.

[00:09:23] Speaker 04:
That's the only thing along the lines of what you're asking.

[00:09:26] Speaker 04:
Why wouldn't somebody take this and put it together?

[00:09:27] Speaker 04:
That's the only thing that the board potentially points to.

[00:09:31] Speaker 04:
The problem with that passage.

[00:09:32] Speaker 02:
Were translucent cams known in the art?

[00:09:34] Speaker 04:
No.

[00:09:35] Speaker 02:
So this patent is the first one that disclosed a translucent cam.

[00:09:41] Speaker 04:
Yes.

[00:09:42] Speaker 04:
And that's why I think this case is similar to Arendy versus Apple and DSS, because what you're dealing with is a limitation that is missing from the art.

[00:09:56] Speaker 01:
The Takasawa discloses a connector with translucent splicing components.

[00:10:02] Speaker 04:
That's right, Judge Laurie.

[00:10:03] Speaker 01:
Discloses translucency.

[00:10:05] Speaker 04:
It discloses that you would have a translucent splicing component and that you would have a spring with an opening in it.

[00:10:14] Speaker 04:
And it teaches you that you don't have to use the spring, but at 1144, column 8, line 49, it's OK if you use something other than the spring, but it has to have the physical opening.

[00:10:26] Speaker 04:
And the problem here is they want to look at Takazawa and take certain snippets out of it

[00:10:34] Speaker 04:
as opposed to looking at it for all that it teaches.

[00:10:39] Speaker 04:
And precisely because you don't have a teaching of translucency with respect to the force applying device, the question then- Well, a component with a property is not a snippet.

[00:10:54] Speaker 04:
Well, I guess the way I'd put it, Judge Laurie, is Takazawa teaches translucent A and have component B with a window.

[00:11:03] Speaker 04:
And they're saying, well, that makes it obvious to have translucent A and B. And my response to that is, OK, well, where's the analysis to show that?

[00:11:10] Speaker 04:
Where is the why?

[00:11:13] Speaker 04:
Why wouldn't the person of ordinary skill in the art with a known solution in hand use that solution?

[00:11:20] Speaker 04:
And the only thing that they've ever suggested is this viewing from a variety of viewing angles.

[00:11:25] Speaker 04:
And it's very important to look at that testimony.

[00:11:28] Speaker 04:
It's page 1027 of the appendix.

[00:11:31] Speaker 04:
And it is not addressing Takizawa at all.

[00:11:36] Speaker 04:
It is making a comparison between the translucent cam and the prior art opaque cam, the solid opaque cam, where what you could potentially do was peek around that solid opaque cam.

[00:11:47] Speaker 04:
It goes to grounds that the board did not institute on.

[00:11:50] Speaker 04:
There is never in either the analysis of their expert or the board's decision any explanation, any reasoning

[00:12:00] Speaker 04:
any logic for why a person of ordinary skill in the art would, instead of using the type of solution suggested by Takazawa, would instead for the first time come up with something completely new.

[00:12:11] Speaker 04:
I see I'm beginning to be in my rebuttal time.

[00:12:13] Speaker 04:
I'm happy to continue answering questions, or I can save the rest of my time and respond on rebuttal.

[00:12:19] Speaker 01:
We will save it for you, Mr. O'Quinn.

[00:12:21] Speaker 04:
Thank you, Judge Laurie.

[00:12:27] Speaker 01:
Mr. Malinda.

[00:12:35] Speaker 03:
Good morning, Your Honors.

[00:12:35] Speaker 03:
May it please the Court?

[00:12:38] Speaker 03:
Before jumping into the specific points that Mr. O'Quinn raised, I'd like to just talk generally about a problem that affects all of the various arguments that Corny makes today and also makes in his brief.

[00:12:51] Speaker 03:
And what the board found was that it misframes the obviousness analysis.

[00:12:55] Speaker 03:
And it found that at A25, A28, and A30 of its final written decision, a personal skill in the art would have started

[00:13:02] Speaker 03:
with the cam light references, which are really only one reference.

[00:13:05] Speaker 03:
They basically all boil down to the cam light connector, various aspects of that.

[00:13:10] Speaker 03:
And Corning does not dispute that all of those various connector components all disclosed that are recited in the claims.

[00:13:17] Speaker 03:
So you've got basically everything in one place.

[00:13:21] Speaker 03:
Then all you have to do is look to Takizawa for its translucency teaching.

[00:13:24] Speaker 03:
That's all we're doing here is making a very simple modification, a minor modification, to the cam mechanism that is already disclosed

[00:13:32] Speaker 03:
in Camelot, and they concede that.

[00:13:34] Speaker 02:
Sure, but there'd never been a translucent cam.

[00:13:37] Speaker 02:
I mean, if there had, you would have cited that as a reference.

[00:13:39] Speaker 03:
Right.

[00:13:40] Speaker 03:
But what the board, what Dr. Dickey said is testified is that, and this is really the crucial part they've hit on that, is he said you'd want to view the splice junction from a variety of different angles.

[00:13:50] Speaker 03:
That's why you would want to make that translucent.

[00:13:52] Speaker 03:
And that's what the board adopted and made its finding in the final written decision, A29.

[00:13:59] Speaker 03:
That testimony is crucial.

[00:14:00] Speaker 03:
viewing angles that personal skill and the heart would use to look at the splice junction, that is your reason to make the modification.

[00:14:07] Speaker 03:
Then Taka's always in the same field.

[00:14:10] Speaker 03:
100 percent, and that's exactly why you combine the references.

[00:14:13] Speaker 03:
And moreover, Mr. Pearson didn't dispute that, and that's a crucial point that the board found in A29, is that this wasn't disputed.

[00:14:22] Speaker 03:
So basically the more translucency you can add to this, the better.

[00:14:25] Speaker 03:
And in fact, they've conceded the limitation regarding to translucent splice components

[00:14:30] Speaker 03:
So keep in mind the splice components work together with the cam mechanism.

[00:14:35] Speaker 03:
So the more translucency the better and therefore you'd have that motivation to modify.

[00:14:38] Speaker 00:
Councilman, let's go ahead and talk at 1142, column 4, line 36.

[00:14:54] Speaker 00:
It says the member component section for clamping the optical fiber in the connection mechanism It's preferably made from and it goes on it says suitably or suitably trans translucent properties Is the member for clamping is that a cam?

[00:15:13] Speaker 03:
Yeah, it's a little confusing there your honor, but I believe they're referring to is the components the components in other words the splice components and

[00:15:19] Speaker 03:
So in other words, those are things that work together with the CAM to do that splicing of the two fibers.

[00:15:26] Speaker 00:
But they are part of the CAM?

[00:15:28] Speaker 03:
It's not really part of the CAM.

[00:15:29] Speaker 03:
They work together with the CAM to bring the two fibers together.

[00:15:35] Speaker 03:
But this evidence that you're zeroing in on, Your Honor, at column four, along with the teachings in column eight, and this is lines of roughly 48 of column eight to column nine, roughly line six.

[00:15:50] Speaker 03:
That plus the testimony from Dr. D. Qusatis is the substantial evidence to affirm the board's finding.

[00:15:57] Speaker 03:
That is really the essence of all of this, individually or collectively.

[00:16:01] Speaker 03:
So I think there's ample substantial evidence to support the motivation to modify, both with respect to Takazawa and Dr. D. Qusatis's interpretation of that evidence, and then application here.

[00:16:14] Speaker 03:
I just wanted to talk about a couple of things that he raised specifically.

[00:16:19] Speaker 03:
First of all, he talks about the fact that tachyzoid doesn't teach the translucent cam.

[00:16:23] Speaker 03:
But again, it teaches the translucent cam splice components that work with that cam.

[00:16:28] Speaker 03:
And that is conceded by Corning, the fact that those splice components are taught in the art.

[00:16:34] Speaker 03:
So it's a very minor baby step to go to than a translucent cam that works with them.

[00:16:39] Speaker 03:
Also, Mr. O'Quinn mentioned that we never identified a particular drawback

[00:16:48] Speaker 03:
with respect to the C-shaped spring.

[00:16:51] Speaker 03:
Well, first of all, I don't believe there's a legal requirement to look for a drawback, particularly when you have an affirmative reason to look at the teachings as a whole that Takazawa provides, which is the C-shaped spring, but also translucency.

[00:17:06] Speaker 03:
That's why it's sort of an irony what they're arguing, which is that we're focusing narrowly on bits and pieces of Takazawa when in reality that's exactly what they're doing by ignoring translucency and focusing only on the C-shaped spring.

[00:17:17] Speaker 03:
Not to mention the fact that the C-shaped spring is a completely different design than the particular thing they call a slider, which is in the cam light connector references.

[00:17:31] Speaker 03:
That's a slider.

[00:17:32] Speaker 03:
It's a very different thing.

[00:17:33] Speaker 03:
So the board finds you wouldn't try to bodily incorporate this C-shaped spring into the cam light connector, particularly because the cam light connector already has a cam in it.

[00:17:45] Speaker 03:
So there'd be no reason to do that.

[00:17:48] Speaker 03:
And I think that's particularly true because you'll notice in the Takazawa C-shaped spring, all that has is a narrow slit.

[00:17:58] Speaker 03:
What the board found was that at A29 is the more translucency the better so that you can see these various viewing angles.

[00:18:04] Speaker 03:
So of course if you made the entirety of the cam translucent, you'd have plenty of viewing angles to look at the splice junction as you're bringing the two fiber optic cables together.

[00:18:19] Speaker 03:
Judge Hughes, you touched upon the standard review here.

[00:18:21] Speaker 03:
The standard review is very hard for them.

[00:18:23] Speaker 03:
And I should emphasize that we have ample substantial evidence, both with respect to the citations in Takazawa, as well as Dr. D.Q.

[00:18:30] Speaker 03:
Saidis' testimony.

[00:18:32] Speaker 03:
As you mentioned earlier, Judge Hughes, in the first argument, many litigants come in arguing that testimony is conclusory.

[00:18:40] Speaker 03:
In fact, they argue that in their briefing.

[00:18:42] Speaker 03:
This is exactly the opposite of conclusory, because we have an actual cogent explanation for why one would have that motivation to modify.

[00:18:49] Speaker 03:
which is maximizing viewing angles.

[00:18:52] Speaker 03:
And again, that's an A1027 to A1028 of the adjoint appendix.

[00:19:05] Speaker 03:
If there are no further questions, just to conclude, substantial evidence supports the board's finding of a motivation to modify the cam of the cam light connector

[00:19:14] Speaker 03:
to arrive at the translucent cam.

[00:19:16] Speaker 03:
That evidence includes Takazawa's teachings of the benefits of translucency.

[00:19:21] Speaker 03:
I'll just direct you to the page sites again, A1142, which is column four, lines 35 through 55, as well as A1144 through A1145, which is 854 through 96.

[00:19:36] Speaker 03:
And in fact, this evidence was so compelling, these are Takazawa's translucency teachings,

[00:19:41] Speaker 03:
that Corning actually attempted to antedate, unsuccessfully, to get rid of Takazawa as part of this analysis.

[00:19:47] Speaker 03:
Clearly, it failed, which is why we're here today.

[00:19:51] Speaker 03:
And I should also point out, of course, Dr. D. Q. Sadis' testimony, that there would be a very strong motivation to arrive at the translucent cam so the person of skill could look at various viewing angles and determine whether or not there was splice continuity.

[00:20:06] Speaker 03:
And I'll refer the court to 1027 through 1028.

[00:20:10] Speaker 03:
as well as his testimony in paragraph 71 at 1031 through 1032.

[00:20:15] Speaker 03:
And then just to close, I'd like to just read a quote from you.

[00:20:21] Speaker 03:
And we cited this case in our standard review section, just to touch on Judge Hughes' point, that if two inconsistent conclusions may reasonably be drawn from the evidence in the record, the PTAB decision to favor one conclusion over the other is the epitome of a decision that must be sustained for review for substantial evidence.

[00:20:39] Speaker 03:
And really, that's exactly what we have here.

[00:20:41] Speaker 03:
Even if there's some sort of factual disagreement about whether you would use translucency or whether or not you would use the C-shaped spring, that ball and strike sort of judgment call should be deferred to by the board, particularly given that we have substantial evidence both in Takazawa as well as Dr. DiCrussella's testimony.

[00:21:01] Speaker 03:
And for those reasons, we believe this court should affirm.

[00:21:05] Speaker 01:
Thank you, counsel.

[00:21:06] Speaker 01:
Mr. O'Quinn has some mobile time.

[00:21:17] Speaker 04:
Thank you, Judge Lurie.

[00:21:19] Speaker 04:
What is going on here is the use of the patent as a template for its own reconstruction, just what this court said you cannot do in Sinsonics.

[00:21:29] Speaker 04:
That's the reason that they pick a collection of prior art that they say would give you a cam, and therefore a translucent cam.

[00:21:40] Speaker 04:
But of course, as this court said in ATD versus Lydell,

[00:21:45] Speaker 04:
what motivates a person of ordinary skill in the art cannot be based on hindsight consideration of components selectively called from the prior art to fit the parameters of the patented invention.

[00:21:56] Speaker 04:
And that is exactly what they are doing by focusing on Takazawa, which teaches translucency for one thing and teaches a physical opening for the thing that they are now trying to apply translucency to.

[00:22:08] Speaker 04:
The only justification that he has is exactly what I told you it was going to be.

[00:22:12] Speaker 04:
He points to the one statement

[00:22:15] Speaker 04:
that you could view from, quote, a variety of viewing angles.

[00:22:19] Speaker 04:
And I encourage you to go back and look at page appendix 1027.

[00:22:24] Speaker 04:
The board cites it.

[00:22:24] Speaker 04:
It block quotes it at appendix 29.

[00:22:27] Speaker 04:
And on that page, there is no discussion, no comparison to Takazawa whatsoever.

[00:22:35] Speaker 04:
He is not talking about or making a comparison to Takazawa's solution.

[00:22:40] Speaker 04:
He is talking about a comparison solely to the use of opaque

[00:22:45] Speaker 04:
cams that were in the prior art.

[00:22:48] Speaker 04:
And so there is nothing that they point to, in fact, to show that a person would be motivated to come up with something other than Takazawa.

[00:22:55] Speaker 04:
Because obviously, what motivates a person of ordinary skill in the art isn't to invalidate a patent

[00:23:00] Speaker 04:
It isn't even to invent something new.

[00:23:02] Speaker 04:
It is to find something that works.

[00:23:04] Speaker 04:
And does Takazawa work?

[00:23:06] Speaker 04:
Their experts said, and this is an appendix 2171, that Takazawa allows one to, quote, easily verify the optical connection and gives a, quote, wide range of directions from which to look.

[00:23:19] Speaker 04:
And so what we're left with is nothing but attorney argument to fill in what is a fundamental failure of proof here.

[00:23:28] Speaker 04:
He says, well, it's just a baby step to go from

[00:23:30] Speaker 04:
having translucent splicing components to saying, you want to have more translucent components.

[00:23:36] Speaker 04:
Well, if it was that obvious to do that, why didn't Dijon?

[00:23:39] Speaker 04:
Or why didn't their expert give some explanation for why it would be obvious to take that step?

[00:23:46] Speaker 04:
Because the one thing he pointed to has nothing to do with translucent cams at all.

[00:23:52] Speaker 04:
And that brings me back to one of the questions that you asked earlier, Judge Hughes, and that's this.

[00:23:57] Speaker 04:
There had never been a translucent cam

[00:24:01] Speaker 04:
in the prior art.

[00:24:02] Speaker 04:
And as this court has held in DSS and in Orendi, when you're talking about a limitation that is missing, the search for a reasoned basis for a person of ordinary skill in the art to modify, to come up with that, has to be searching.

[00:24:20] Speaker 04:
And that is what is lacking here, as well as no analysis by the board whatsoever of

[00:24:28] Speaker 04:
the, quote, existence of a prevalent method of achieving the limitation at issue, end quote, which this court found was prejudicial for the board not to do in a remedy versus apple.

[00:24:41] Speaker 04:
And so based on that, I think what you have is not just an issue vis-a-vis substantial evidence, which is lacking, but a legal error by the board by failing to engage in the kind of analysis that is required based on the priority that was presented to the board.

[00:24:57] Speaker 04:
I'm happy to answer any additional questions that the panel may have, but we would urge the court to reverse with respect to the claims that we have appealed.

[00:25:06] Speaker 01:
Thank you, counsel.

[00:25:07] Speaker 01:
The case is submitted.

[00:25:08] Speaker 04:
Thank you, Judge Lurie.