[00:00:42] Speaker ?:
Thank you.

[00:01:08] Speaker 03:
OK, the next argued case is number 18, 1904, Halko Foundry and Machine Company against GMS mine repair.

[00:01:18] Speaker 03:
Mr. Lawrence.

[00:01:25] Speaker 04:
May it please the court, on behalf of GMS, my name is James Lawrence.

[00:01:30] Speaker 04:
Your honors, design patent protection does not provide monopoly rights and design concepts.

[00:01:38] Speaker 04:
Conceptual similarities between a patented device and an accused product are insufficient to provide a basis for infringement.

[00:01:48] Speaker 04:
This court has a long line of precedent protecting against the overextension of design patents.

[00:01:59] Speaker 04:
This court has recently, as its 2016 sport dimension decision,

[00:02:06] Speaker 04:
instructed that district court must take into account claim construction to avoid these kinds of problems.

[00:02:15] Speaker 02:
One of the concerns I have about the argument you're making right now is that that's true.

[00:02:20] Speaker 02:
Our case law does say that, but I don't see where you've appealed the district court's claim construction.

[00:02:28] Speaker 04:
Your Honor, we, GMS would maintain that the

[00:02:33] Speaker 04:
claim construction issue is embodied in the overall infringement analysis, which is on appeal here and is part of our first argument in our opening brief.

[00:02:42] Speaker 02:
In a utility patent context, we wouldn't understand somebody's raising of the factual dispute of infringement to include raising dispute in claim construction.

[00:02:52] Speaker 02:
Why should we do that with respect to design patents in your case?

[00:02:56] Speaker 04:
Well, Your Honor, in order to analyze whether or not the

[00:03:01] Speaker 04:
A jury verdict here is supported by the record.

[00:03:04] Speaker 04:
The initial step that this Court would have to engage in is to appropriately construe the patent, which we maintain is subject to a de novo review as a matter of law to this Court's review.

[00:03:18] Speaker 02:
I understand what you're saying, but nobody complained, at least initially, about how the district court construed the claim.

[00:03:25] Speaker 04:
Well, Your Honor, at Apex 159 to 164 in the record,

[00:03:30] Speaker 04:
GMS in the district court raised the issue of claim construction functionality and there was a Markman hearing in this case and a proposed construction of the design patent that took into account this court's teaching in sport dimension.

[00:03:51] Speaker 02:
Where is it raised in the opening brief?

[00:03:56] Speaker 04:
I would point the court to

[00:03:59] Speaker 04:
our discussion in Section 1 of GMS's argument, Subsection C, pages 14 through 18, where the construction or an attempt is made to describe what the 684 patent covers and how that

[00:04:26] Speaker 04:
how that has to be considered in light of the very functional aspects that are at issue in the claim design here.

[00:04:36] Speaker 02:
So I understand you to be saying that here you've said that the claim has a very limited scope.

[00:04:42] Speaker 02:
I think that's the very language that you use on page 14 in your heading.

[00:04:46] Speaker 02:
So your position is that even though you didn't, as an issue, also dispute the district court's claim construction, that you've said enough here in order to preserve this issue.

[00:04:56] Speaker 04:
Yes, Your Honor.

[00:04:58] Speaker 02:
Should I look anywhere else besides page 14 for that?

[00:05:01] Speaker 04:
You can look at page 14.

[00:05:04] Speaker 04:
You can also look later on to page 16 through 17, where there is a discussion of the functionality issues which inform the court's construction of the GMS maintain should have informed the district court's construction of this path.

[00:05:26] Speaker 04:
as well as in the reply brief where we raised the issue.

[00:05:31] Speaker 04:
I believe it was on page 18 or page 17 in the reply brief, citing to the de novo standard review for claim construction and suggesting that that can also be a basis for the court to remand to provide a new trial on the issue of infringement under an appropriate claim construction that takes into account this court's teachings and support dimension in other cases.

[00:06:01] Speaker 04:
As I mentioned, Your Honor, claim construction consistent with the sport dimension decision and other cases provided by this Court were not, was not done in this case.

[00:06:14] Speaker 04:
At Apex 323, the district court, after having in front of it a claim construction that took into account sport dimension, simply made a very brief order where it sent the claim

[00:06:30] Speaker 04:
claim construction eventually that got to the jury that simply incorporated the claim on the face of the patent and directed the jury's attention to the figures.

[00:06:44] Speaker 04:
And as a result, the jury in this case returned a verdict of infringement against GMS, a verdict that was based on similarities in concept and also similarities that were functional and prior art as well.

[00:06:59] Speaker 04:
I'd like to raise three points in support of GMS's position, Your Honors, that what is appropriate here is a finding of no infringement as a matter of law.

[00:07:13] Speaker 04:
First is that the scope of the 684 patent is narrow.

[00:07:19] Speaker 04:
Second is that when this patent is properly understood and construed, there are significant striking visual

[00:07:29] Speaker 04:
dissimilarities from every perspective.

[00:07:32] Speaker 04:
Third is that the products at issue in this case are not impulse purchases.

[00:07:37] Speaker 04:
These are expensive pieces of equipment that are purchased by employees in coal mines tasked with keeping coal miners safe.

[00:07:48] Speaker 04:
So they would exercise care and discretion in purchasing these products.

[00:07:54] Speaker 04:
With respect to the first point,

[00:07:57] Speaker 04:
And this is, I don't want to belabor the point in the brief because we spend a significant amount of time in the opening brief talking about what is claimed here and what is claimed here is quite a bit.

[00:08:09] Speaker 04:
Insolid lines are essentially every feature of the device at issue, the squared lid that protrudes out the side of the standard 55-gallon drum, a frustroconical,

[00:08:25] Speaker 04:
base with eight legs, a egg-shaped device to facilitate flow of air in and out of the device.

[00:08:35] Speaker 04:
Havco here chose, as the patentee, to claim each and every aspect of its device.

[00:08:43] Speaker 04:
So simply on the face of the patent alone, that choice suggests the limited scope in this case.

[00:08:55] Speaker 04:
Further, when the court takes into account, consistent with sport dimension, which commands district courts to engage in a functionality analysis, the items that are claimed are highly functional, the 55-gallon drum, the lid, the stand.

[00:09:16] Speaker 04:
And we've cited, Your Honors, two particular portions in the concomitant utility patent, the 401 patent.

[00:09:23] Speaker 04:
I would focus the court's attention

[00:09:25] Speaker 04:
on Apex 172, column 2, to Apex 173, column 3, where each and every element of the visual presentation is described and is, and the functional aspects of those elements are detailed.

[00:09:46] Speaker 04:
The standard conventional drum being an economic convenient choice for the structure of the product.

[00:09:53] Speaker 04:
The frustoconical stand

[00:09:55] Speaker 04:
providing the ability, along with the drum, to roll this device in coal mines.

[00:10:02] Speaker 04:
The lid preventing the admission of unwanted debris.

[00:10:07] Speaker 01:
All of it.

[00:10:07] Speaker 01:
The question is, a couple things, but the first question is, the way this product looks, is it essential to perform the function of dust blowing?

[00:10:21] Speaker 01:
I mean, you need a container, of course, but does the container have to look like this particular container?

[00:10:29] Speaker 04:
Your Honor, conceivably, and I don't think GMS can do it otherwise at trial or in the briefs, conceivably there are alternative ways to design a rock dustblower.

[00:10:45] Speaker 04:
We would maintain that the optimal way would be to incorporate a cylindrical configuration because

[00:10:51] Speaker 04:
As noted in our brief, the cylindrical container, as described at Apex 173 column 3, provides for flow of the rock dust through the device without cavitation and other disruptions of the dust.

[00:11:12] Speaker 04:
And the other functional aspect is it allows for rolling.

[00:11:16] Speaker 04:
We would also point out that in sport dimension,

[00:11:19] Speaker 04:
functionality was taken into account and it was part of the claim construction analysis, even though theoretically there will be alternative ways to design the arm bands that were at issue in that personal flotation case.

[00:11:36] Speaker 04:
So we would maintain that it's still, even if there were alternative ways to design the product at issue,

[00:11:46] Speaker 04:
Claim construction functionality is still an issue, and it's an issue that wasn't addressed at the district court level.

[00:11:52] Speaker 04:
And once the claim construction was entered and the jury was instructed, they focused on the jury, that is, focused on conceptual similarities and functional aspects of the design that ultimately led to the verdicts.

[00:12:10] Speaker 01:
Did you present evidence on all these functionality arguments to the jury?

[00:12:16] Speaker 04:
The, and I would note we did not, my colleague Mr. Biller and I did not try the case.

[00:12:22] Speaker 04:
But our, our, our read of the record is that the functional, the functional considerations weren't presented to the jury.

[00:12:30] Speaker 04:
One issue there, your honor, was that half co, I believe, worked very hard to prevent any discussion of the functional aspects of the design.

[00:12:41] Speaker 04:
I think there were objections within the opening statement when

[00:12:44] Speaker 04:
trial counsel attempted to talk about what we talk about in the record, which is at Apex 590, Mr. Fornacci and the origins of this design, the vacuum cleaner that incorporated a 55-gallon drum, this design essentially reversed that.

[00:13:04] Speaker 04:
that that opportunity was cut off.

[00:13:05] Speaker 02:
Were you suggesting that because of that colloquy at page A590, counsel thought that they couldn't talk about the functional aspects of the patent claim at all?

[00:13:20] Speaker 02:
Or present any evidence of what you're talking about today?

[00:13:24] Speaker 04:
Well, Your Honor, it's hard.

[00:13:27] Speaker 04:
I don't know what was in trial counsel's mind in that regard.

[00:13:31] Speaker 04:
But even so,

[00:13:34] Speaker 04:
The claim construction issue was in front of the court, again, at Apex 159 through 164.

[00:13:41] Speaker 04:
And the lessons of sport dimension, ethicon, and other cases were there to be gleaned.

[00:13:46] Speaker 04:
And the district court didn't take the opportunity to reach out and provide a construction that would be consistent with this court's precedent.

[00:13:53] Speaker 03:
Are you telling us that there were requested jury instructions that were rejected?

[00:13:59] Speaker 04:
Your Honor, we do not maintain that.

[00:14:02] Speaker 04:
And in the briefing and the opening brief and the reply brief, I believe, we don't contest, GMS doesn't contest, the jury instructions that accord with the view that we take in this case were actually in front of the jury that we had presented, my client had presented.

[00:14:23] Speaker 02:
What about turning to the prior art issue?

[00:14:27] Speaker 02:
Were jury instructions presented

[00:14:30] Speaker 02:
discussing the prior art aspect and the jury's need to consider prior art?

[00:14:36] Speaker 04:
They were not, Your Honor.

[00:14:38] Speaker 04:
And as we discussed in the briefing, we believe that's subject to a plain error or standard review.

[00:14:44] Speaker 04:
It's not something we maintain was preserved at the trial court level.

[00:14:48] Speaker 02:
Was there any attempt to introduce prior art to the jury and talk to them about the role of prior art?

[00:14:55] Speaker 04:
The prior art, Your Honor,

[00:14:58] Speaker 04:
GMS Maintains was introduced on direct examination by Hafco, actually, through its co-president and chief engineer, Mr. Fornasi, who talks about at Apex 590 through 591, and importantly, the fact that the 55-gallon drum is a standard 55-gallon drum.

[00:15:23] Speaker 04:
But it wasn't.

[00:15:24] Speaker 02:
So the jury had that fact before it.

[00:15:26] Speaker 04:
It did have that fact before it.

[00:15:30] Speaker 01:
But it didn't have that fact before it in the context of this being prior art that the jury needed to understand in the context of understanding the claim.

[00:15:41] Speaker 04:
That's correct, Your Honor.

[00:15:43] Speaker 04:
It did not.

[00:15:45] Speaker 04:
With that, I'd like to reserve a balance of my time for rebuttal.

[00:15:49] Speaker 03:
All right, we'll save you some extra rebuttal, and let's hear from the other side.

[00:15:53] Speaker 04:
Thank you.

[00:16:02] Speaker 00:
May it please the court counsel?

[00:16:04] Speaker 00:
Mr. Fresco.

[00:16:05] Speaker 00:
I'd like to address the last issue first, Your Honor.

[00:16:08] Speaker 00:
We strenuously disagree that the prior art was entered into the case in any manner.

[00:16:14] Speaker 00:
There was questioning of the officer and engineer of HAPCO

[00:16:18] Speaker 00:
about the design of the Hasbro product, in which he admittedly said, this is a standard type drum to which were attached certain devices.

[00:16:27] Speaker 00:
And I'm paraphrasing.

[00:16:28] Speaker 00:
But it was never stated that these 55-gallon drum was essential, that it was prior art.

[00:16:34] Speaker 00:
In fact, the patent reads on its face, if we look at the patent as construed by the court, as simply a cylindrical device to which the other mechanisms are attached.

[00:16:43] Speaker 00:
Now, the fact is prior art was not raised.

[00:16:47] Speaker 00:
Appellant here attempts to argue that the jury verdict must be set aside because the instructions were improper.

[00:16:56] Speaker 00:
The jury was properly instructed.

[00:16:58] Speaker 00:
It was not instructed in prior art because prior art was not in the case.

[00:17:02] Speaker 00:
The case law in this circuit and the federal circuit is clear that the burden of producing prior art is on the person challenging the patent.

[00:17:11] Speaker 00:
They did not produce a shred of evidence of trial, and I tried the case.

[00:17:16] Speaker 00:
as to the prior art.

[00:17:19] Speaker 00:
The only thing they can point to is that Mr. Foronacci said, this is a standard kind of drum.

[00:17:24] Speaker 00:
That isn't prior art.

[00:17:26] Speaker 00:
In fact, they mention in their brief that the patent itself claims or discloses the patent on a 55 gallon drum that was issued, I believe, in 2012.

[00:17:38] Speaker 00:
The jury had the patent, but they didn't know what

[00:17:42] Speaker 00:
those particular prior art references were.

[00:17:44] Speaker 00:
There was no effort to bring them in.

[00:17:46] Speaker 00:
There was no effort to present any evidence at all on behalf of GMS, let alone evidence by experts or anyone else as to whether prior art was embodied in the half co-invention.

[00:17:57] Speaker 00:
They had the opportunity to seek claim construction.

[00:17:59] Speaker 00:
They asked for a markman hearing, even though we know under Egyptian goddess and later president, if it's not frowned upon, at least it's discouraged in the case of a design patent.

[00:18:11] Speaker 00:
After a hearing at which they presented no evidence on their proposed claim construction, Judge Fabric denied it.

[00:18:17] Speaker 00:
He said he was defining the patent as per the drawings in the patent itself.

[00:18:23] Speaker 00:
And that was his claim construction.

[00:18:25] Speaker 00:
At the same time, they moved for a declaration of invalidity, and he denied that also.

[00:18:30] Speaker 00:
The case went to trial.

[00:18:32] Speaker 00:
The case was tried to the jury.

[00:18:34] Speaker 00:
We presented evidence.

[00:18:35] Speaker 00:
We presented one of their witnesses adversely in the rest of our case.

[00:18:39] Speaker 00:
And after that,

[00:18:41] Speaker 00:
GMS moved for a directed verdict.

[00:18:44] Speaker 00:
The judge denied the directed verdict and he said clearly that he thought there was sufficient material, substantial evidence that would allow a jury to find for the plaintiff, and he was going to allow it to go to the jury.

[00:18:59] Speaker 00:
There was no motion for a summary judgment on the issue of functionality that's been discussed, the issue of invalidity.

[00:19:05] Speaker 00:
Instead, the case went to the jury.

[00:19:08] Speaker 00:
on the instructions that were tendered and accepted by the court.

[00:19:11] Speaker 00:
There was no instruction referencing prior art.

[00:19:13] Speaker 02:
Can I interrupt you for a minute?

[00:19:14] Speaker 00:
Sorry.

[00:19:14] Speaker 02:
Was there any prohibition on the accused infringer's ability to present evidence that the design was really largely functional?

[00:19:27] Speaker 00:
No prohibition, Your Honor.

[00:19:29] Speaker 00:
There was just no evidence presented.

[00:19:31] Speaker 00:
I frankly probably would have objected to it.

[00:19:34] Speaker 00:
There was no evidence presented and to my recollection there was no ruling on that at all by the court.

[00:19:39] Speaker 00:
And candidly, in the arguments that were made at the markman stage and later in the briefing in this case, GMS ignores precedent and instead tries to argue component by component, element by element, this element compares to this one, all these elements look the same.

[00:19:58] Speaker 00:
Well, the fact is

[00:19:59] Speaker 00:
It's a unitary design.

[00:20:01] Speaker 00:
The patent protects the unitary design, and they have to look at the design as a whole.

[00:20:05] Speaker 00:
The jury saw all the evidence, heard the credibility of the witnesses, reviewed that evidence, and within two hours came back and found infringement and willful infringement.

[00:20:16] Speaker 00:
Now, the issue is not whether they both have a stand and whether the two stands are the same.

[00:20:20] Speaker 00:
The issue is to an ordinary observer, and the law is clear, and I have the case here if we need to cite it, that a jury is comprised of ordinary observers.

[00:20:30] Speaker 00:
that the design of their product was disturbingly or similar to, substantially similar to under the test, to our patent.

[00:20:42] Speaker 00:
And it would confuse an ordinary observer to the extent that the ordinary observer might purchase their product thinking it was ours.

[00:20:50] Speaker 00:
Now, Judge Faber saw there was sufficient evidence to go to the jury.

[00:20:55] Speaker 00:
The jury reviewed the evidence.

[00:20:56] Speaker 00:
The jury found for the plaintiff.

[00:20:58] Speaker 00:
And what GMS now seeks to do is re-litigate the factual issues in this court.

[00:21:03] Speaker 00:
And this is not the place for it.

[00:21:05] Speaker 00:
We have, as was noted in a dissent in which Judge Newman participated in the, I believe it was the Arctic Cat case or, no, it was the Phillips case, Phillips and AWH case.

[00:21:18] Speaker 00:
We have a rule that we must provide deference to factual findings by the trial judge.

[00:21:24] Speaker 00:
We can't lightly turn those aside because we may disagree.

[00:21:28] Speaker 00:
in our view of what the facts may have shown.

[00:21:31] Speaker 00:
If the court has made these findings, seeing the evidence, hearing the witnesses, we should be very reluctant to overturn the court at that point, particularly in this case where you've been through the markman hearing, the markman process, you've been through the directed verdict motion, you've been through the motion for a declaration of infringement, you've been to a jury, and the jury has found for the plaintiff, and they found willfulness to argue now that we should look instead to the fact that both of these machines had bases.

[00:21:57] Speaker 00:
Both of these machines had lids.

[00:21:59] Speaker 00:
Both of these cylinders had ribs.

[00:22:02] Speaker 00:
If they had a functional purpose or a functional aspect, it doesn't matter.

[00:22:08] Speaker 00:
The case law is clear that you can have something that has a function, but still be part of the overall design.

[00:22:12] Speaker 00:
The question is, what did it look like, not what did it do?

[00:22:18] Speaker 00:
And in our case, we submit to you that the 55-gallon drum is not essential.

[00:22:23] Speaker 00:
In fact, there was testimony from the same witness, Mr. Fornacci,

[00:22:27] Speaker 00:
who said, basically, you need a cylinder.

[00:22:30] Speaker 00:
And Mr. Helbig, the GMS officer, we called adversely.

[00:22:35] Speaker 00:
And Mr. Helbig said they had even made one using a smaller container.

[00:22:40] Speaker 00:
You don't have to use a 55-gallon drum.

[00:22:42] Speaker 00:
The 55-gallon drum is claimed in the 401 utility patent.

[00:22:46] Speaker 00:
We didn't sue on the 401 utility patent.

[00:22:49] Speaker 00:
We sued instead on the design patent.

[00:22:52] Speaker 00:
Our claim is that their product as a whole looks like our product deceptively.

[00:22:57] Speaker 00:
and meets the standard to allow us to claim infringement.

[00:23:01] Speaker 00:
The judge agreed, the jury agreed.

[00:23:05] Speaker 00:
Be happy to answer any questions.

[00:23:07] Speaker 03:
Any questions for counsel?

[00:23:11] Speaker 03:
Any questions for counsel?

[00:23:15] Speaker 01:
What happened to the utility patent?

[00:23:17] Speaker 01:
Pardon me?

[00:23:17] Speaker 01:
How come you didn't allege utility patent?

[00:23:24] Speaker 00:
We made a decision among council.

[00:23:26] Speaker 00:
We didn't prosecute the patent.

[00:23:27] Speaker 00:
We made a decision with the prosecutory patent that we should not proceed under the utility patent because it did, in fact, involve a 55-gallon drum.

[00:23:36] Speaker 00:
And the 55-gallon drum was, by that time, prior art.

[00:23:39] Speaker 00:
There was a patent on it by that point.

[00:23:42] Speaker 00:
So that decision was made that we had a better case, frankly, on the utility patent.

[00:23:49] Speaker 03:
Anything else?

[00:23:50] Speaker 03:
Anything else?

[00:23:51] Speaker 03:
Thank you.

[00:23:52] Speaker 00:
Thank you.

[00:23:56] Speaker 03:
Okay, Mr. Lawrence.

[00:23:59] Speaker 04:
Briefly, Your Honors, functionality, excuse me, functionality wasn't raised substantially at the trial because the claim construction that the court ultimately provided, a claim construction again that had the utility patent as part of the overall consideration introduced at the Markman hearing,

[00:24:23] Speaker 04:
also part of the briefing on the claim construction.

[00:24:25] Speaker 02:
Do you stand behind the claim construction that your client proposed at page A164?

[00:24:30] Speaker 02:
Your Honor, I... I... I mean, in order to preserve claim construction, I suppose you need to stick to that position, right?

[00:24:52] Speaker 04:
I don't know if we would have to stick to the verbal descriptions provided at 164, Apex 164.

[00:25:05] Speaker 04:
We would maintain that there was no consideration given at all to the functional aspects of the device that's at issue in this case.

[00:25:16] Speaker 03:
But you told us you didn't ask for consideration of the functional aspects.

[00:25:22] Speaker 04:
Well, Your Honor, we did at the Markman stage.

[00:25:26] Speaker 02:
Well, then this would be your position that's preserved at the Markman stage, right?

[00:25:31] Speaker 02:
Yes, that's correct.

[00:25:32] Speaker 02:
H.A.

[00:25:32] Speaker 02:
164?

[00:25:34] Speaker 04:
That's correct, Your Honor.

[00:25:36] Speaker 02:
Is that addressed in your briefing on appeal?

[00:25:39] Speaker 04:
The particular construction that's proposed there is not.

[00:25:48] Speaker 04:
Finally,

[00:25:53] Speaker 04:
And again, to my colleagues, to address my colleague's point, even under Egyptian goddess, 543F3 at 680, under that case, which was decided, I believe, in 2008, and subsequent decisions by this court and sport dimension instruct, it's not in clear equivocal terms in Egyptian goddess, but sport dimension, which quotes odds on products from 1997, says,

[00:26:23] Speaker 04:
You, the district court must, must engage in an identification of the non-functional elements of a design as part of the claim construction process where there are functional and non-functional aspects of a design claimed.

[00:26:40] Speaker 04:
And that simply did not happen here.

[00:26:43] Speaker 04:
Once the claim construction went in front of the jury, the jury found infringement on the basis of conceptual similarities.

[00:26:49] Speaker 02:
Doesn't Egyptian goddess being an end bank case, isn't that the case that we should follow?

[00:26:54] Speaker 02:
And to the extent it says that the district court may or should or could in many cases construe the claims to distinguish the functional from the non-functional, there's other ways that it could be done?

[00:27:06] Speaker 04:
I believe the exact language of Egyptian goddess, your honor, can take into account

[00:27:15] Speaker 04:
However, the Sport Dimension case.

[00:27:17] Speaker 02:
But Sport Dimension can't overrule an M-Bank case, right?

[00:27:21] Speaker 04:
And it's just a penal decision.

[00:27:23] Speaker 04:
That's correct.

[00:27:24] Speaker 04:
I would note, Your Honor, though, that at 680, at 543, at 680, the Egyptian goddess court actually quotes the exact same passage from odds on products with respect to must.

[00:27:40] Speaker 04:
The district court must perform this analysis.

[00:27:43] Speaker 04:
I see I'm out of time.

[00:27:45] Speaker 04:
conclude?

[00:27:47] Speaker 03:
All right, you get the last word.

[00:27:49] Speaker 04:
Sure.

[00:27:49] Speaker 04:
Your Honor, we ask that the court vacate the jury verdict and find no infringement as a matter of law in this case, and in the alternative, remand the case back to the district court for a claim construction that takes into account this court's decision in sport dimension and others for a new trial on liability.

[00:28:13] Speaker 03:
Thank you.

[00:28:15] Speaker 03:
Thank you.

[00:28:16] Speaker 03:
Thank you both.

[00:28:18] Speaker 03:
This concludes this morning's arguments.

[00:28:21] Speaker 00:
Thank you.

[00:28:23] Speaker ?:
All right.