[00:00:00] Speaker 04:
As I said, the case is 21-1191, NRA, Google, LLC, appeal from the United States Patent and Trademark Office, the Patent Trial and Appeal Board.

[00:00:10] Speaker 04:
Ms.

[00:00:13] Speaker 04:
Curtis, you want five minutes for rebuttal?

[00:00:16] Speaker 04:
All right.

[00:00:17] Speaker 04:
In between, we might, before we get to rebuttals, we're going to have to move the camera back out.

[00:00:23] Speaker 04:
So you'll have to let us know when that happens.

[00:00:32] Speaker 00:
Good afternoon, Your Honor.

[00:00:33] Speaker 00:
This might please the court.

[00:00:35] Speaker 00:
I'm Tara Curtis here on behalf of Appellant Google LLC.

[00:00:39] Speaker 00:
Unless Your Honors prefer otherwise, I'd like to start with the individualized notification element.

[00:00:44] Speaker 00:
Specifically, I'll talk about what that notification means and why the speed by reference does not teach it.

[00:00:50] Speaker 00:
And then I'll discuss the predetermined threshold element.

[00:00:53] Speaker 00:
Fundamentally here, the board misunderstood the individualized nature of the claim notification step.

[00:01:01] Speaker 00:
If you look at the- Excuse me, can you speak up a little bit?

[00:01:03] Speaker 00:
These things make it difficult.

[00:01:05] Speaker 00:
Apologies.

[00:01:06] Speaker 00:
If we look at the language of the claims, specifically claim one, it's on appendix page 13 for your reference.

[00:01:15] Speaker 00:
The notification here is specific to the level of relevancy for an individual.

[00:01:23] Speaker 00:
We know that looking at not only that final limitation with the notification step in it, but the previous, the second to last limitation, where the claim requires determining for each user of the predetermined group of users a level of relevancy for a predetermined object.

[00:01:41] Speaker 04:
The board found that this issue was not actually raised, that it was waived.

[00:01:48] Speaker 04:
government argues that in fact it has been waived and that it can't be presented for the first time here in appeal.

[00:01:55] Speaker 04:
What precise language from your briefing below do you rely upon to say that it was sufficiently raised?

[00:02:02] Speaker 00:
Sure, so respectfully Your Honor, the board did not find and make any findings with respect to this particular argument.

[00:02:08] Speaker 00:
It was just the director that argued waiver on appeal but

[00:02:13] Speaker 00:
Looking at Google's briefs to the board, we see this argument was certainly raised and has been Google's argument throughout the proceedings.

[00:02:23] Speaker 00:
If we look at appendix page 543, there's that paragraph at the bottom of the page where Google is distinguishing SPIVAS from its claims.

[00:02:40] Speaker 00:
And it specifically says that SPVAC is only teaching this customized media content.

[00:02:46] Speaker 00:
So that's essentially filtering content so that a user can see.

[00:02:50] Speaker 02:
I'm sorry.

[00:02:51] Speaker 02:
You were on 543?

[00:02:53] Speaker 02:
Yes, that's correct.

[00:02:54] Speaker 02:
And roughly where on 543?

[00:02:57] Speaker 00:
So the first paragraph that's not indented?

[00:03:00] Speaker 03:
That is SPVAC at most?

[00:03:01] Speaker 00:
Correct.

[00:03:02] Speaker 03:
OK.

[00:03:02] Speaker 00:
Correct, Your Honor.

[00:03:04] Speaker 00:
So that first sentence,

[00:03:07] Speaker 00:
Google is distinguishing Spivak from the claims, saying that Spivak is only teaching the filtering content.

[00:03:15] Speaker 00:
And then if we look down about four lines, the sentence begins, however, nowhere does Spivak teach or suggest that such alerts can be in any way related to trends applied to users.

[00:03:27] Speaker 00:
So there, Google is specifically saying, Spivak teaches this filtering content.

[00:03:32] Speaker 00:
It does not teach applying trends to users.

[00:03:36] Speaker 00:
And then it goes on, Google's brief goes on to say, let alone just SPVAC apply trends to users who meet a particular level of relevancy for an identified object.

[00:03:47] Speaker 04:
And that is the exact- But that still talks about users generally as opposed to specific users, correct?

[00:03:53] Speaker 00:
Well, Your Honor, I would disagree with that respectfully.

[00:03:55] Speaker 00:
The reliance on the level of relevancy of an identified object is only for individual users.

[00:04:03] Speaker 00:
And again, if we look at that final or the second to last limitation in the claims, that determining the level of relevancy for each user, the only relevancy determination that is ever made in the claims is for individual users.

[00:04:19] Speaker 00:
And so here, Google has referred specifically back to the relevancy of an identified object.

[00:04:24] Speaker 00:
That is relevancy for an individual user.

[00:04:28] Speaker 00:
And again, Google raised this argument.

[00:04:29] Speaker 04:
So you're saying that the board needed to take this and then to interpret this sentence by going back into the patent to see what you might have meant by this sentence?

[00:04:41] Speaker 00:
Well, I think it's clear on its face, Your Honor.

[00:04:43] Speaker 00:
But there's even clearer language in Google's reply brief to the board.

[00:04:48] Speaker 00:
If we look at appendix 568, I'll give you a moment to get there.

[00:04:56] Speaker 00:
Again, we're looking at the first paragraph that's not indented The argument that Google is making here is again distinguishing speed back from the claims the first sentence says that is Speed back at most teaches determining relevance of a message or piece of content to a group of users to a group of users that is

[00:05:20] Speaker 00:
completely different than identifying a trend for an individual user, which is what the claims are directed to.

[00:05:26] Speaker 00:
And again, Google uses similar language in the next sentence.

[00:05:30] Speaker 00:
However, nowhere does feedback teachers suggest a notification indicating a current trend applied to users, let alone to users

[00:05:41] Speaker 00:
with the level of relevancy of an identified object.

[00:05:43] Speaker 04:
Did you file a motion asking the board to reconsider on grounds that you believed the board misunderstood your arguments?

[00:05:54] Speaker 00:
We did not file a motion for reconsideration, Your Honor, but that's not a requirement before bringing in appeal.

[00:06:00] Speaker 04:
Well, I understand that.

[00:06:00] Speaker 04:
But in this particular case, the board obviously didn't think you raised this issue because it never addressed it.

[00:06:06] Speaker 00:
That's correct, Your Honor.

[00:06:07] Speaker 00:
And that's unfortunate that the board didn't understand

[00:06:11] Speaker 00:
the argument that Google was making.

[00:06:13] Speaker 00:
But I think the references I've cited and the record as a whole show that Google did make this argument repeatedly.

[00:06:21] Speaker 00:
The examiner only ever found that the prior applied trends to a group of users.

[00:06:28] Speaker 00:
The board made that same mistake.

[00:06:29] Speaker 00:
And so here we are on appeal.

[00:06:33] Speaker 00:
requesting that determination be reversed.

[00:06:39] Speaker 00:
So if we look at the specification of this application as a whole, we can see that it is really this individualized determination that is being claimed.

[00:06:52] Speaker 00:
And the invention here was moving away from applying trends to a group or to aggregated demographic populations and moving towards

[00:07:02] Speaker 00:
that more particular individualized targeted advertising.

[00:07:07] Speaker 04:
What do we do about the fact that the claim says one or more?

[00:07:10] Speaker 04:
It doesn't say one user.

[00:07:12] Speaker 00:
Sure.

[00:07:12] Speaker 00:
So the one or more language, Your Honor, is just saying repeat this process for each user within your predetermined group.

[00:07:20] Speaker 04:
Where in the written description is that made clear?

[00:07:23] Speaker 04:
I'm sorry, what was that?

[00:07:24] Speaker 04:
Where in the written description is that made clear?

[00:07:27] Speaker 00:
Sure.

[00:07:28] Speaker 00:
If we look at, I believe it's Appendix 185,

[00:07:32] Speaker 00:
Paragraph 34 and 35 describes the notification that is being sent to vendors.

[00:07:45] Speaker 00:
In paragraph 34, it states that the vendors can be notified on satisfaction of certain predetermined conditions.

[00:07:53] Speaker 00:
And then paragraph 35 goes on to indicate what that notification might say.

[00:08:00] Speaker 00:
So, for example, a vendor might get notified about trends relating to products.

[00:08:06] Speaker 00:
And if we look at the third line, about halfway through there's a comma and then it states, identifies users associated with those trends.

[00:08:14] Speaker 00:
So there the specification is saying that the notification can identify the particular users associated with the trend.

[00:08:21] Speaker 00:
And then farther down in that paragraph, the specification states that

[00:08:27] Speaker 00:
the vendor can choose to vary.

[00:08:30] Speaker 00:
I'm sorry, which paragraph are you in right now?

[00:08:32] Speaker 02:
35, Your Honor.

[00:08:33] Speaker 00:
And now I'm looking at, let me see, one, two, three, four, the fifth line down, the cost of placing an advertisement may be set based on a value for a selected user or for a group.

[00:08:45] Speaker 00:
And so it's making a distinction.

[00:08:47] Speaker 00:
You know, there could be, Google could have claimed notifying vendors about trends applying to groups.

[00:08:55] Speaker 00:
That's not what it did.

[00:08:56] Speaker 00:
There is written description support for notifications about a particular user.

[00:09:03] Speaker 00:
And then even the next sentence states that the value may be further based on how relevant the trend is to an identified user.

[00:09:10] Speaker 00:
And again, that's pulling in that second to last, that second to last limitation, determining the level of relevance for one particular individual user.

[00:09:20] Speaker 00:
And then back to your question, Judge Amali,

[00:09:24] Speaker 00:
you know, taking that individualized user relevancy determination and applying it across the board to all of the different users in the predetermined group.

[00:09:35] Speaker 00:
Speedback simply does not teach that individualized relevancy determination.

[00:09:41] Speaker 00:
The board relied on two different aspects of Speedback as allegedly teaching that limitation, and neither of them fit the bill.

[00:09:50] Speaker 00:
The first is the desktop alerts.

[00:09:52] Speaker 00:
And what those alerts are essentially doing is taking incoming social media content, filtering it based on some settings that the user has set, and then showing it to the user, and in some cases, in the form of a desktop alert.

[00:10:09] Speaker 04:
There's no discussion of- If what you really want is to be focused on a single user as opposed to user groups, why don't you just propose to amend the claim to make that clear?

[00:10:22] Speaker 00:
Your Honor, we believe the language is clear from what was used in the claims.

[00:10:27] Speaker 00:
It's that one or more users, Google could have perhaps claimed one user and then a final limitation stating repeat for all users.

[00:10:37] Speaker 00:
But it's more concise, I think, to use the language that we used.

[00:10:42] Speaker 00:
And I think that the support is there.

[00:10:43] Speaker 04:
When you say more concise, it's more broad.

[00:10:47] Speaker 00:
More concise in terms of word usage, Your Honor.

[00:10:51] Speaker 00:
And in any event, SPVAC doesn't teach that sort of trend to individual user relevancy determination.

[00:11:01] Speaker 00:
And there's an additional problem with the board's analysis here beyond the SPVAC issue, and that's the predetermined threshold issue that the board relied on Zhang for.

[00:11:11] Speaker 00:
And I see I'm into my rebuttal time, so I'll summarize it briefly.

[00:11:15] Speaker 00:
Zhang doesn't teach any sort of relationship between

[00:11:19] Speaker 00:
the predetermined threshold and sending the notification.

[00:11:23] Speaker 00:
That's really a crucial element of the claims here.

[00:11:27] Speaker 00:
If there are no users that satisfy the predetermined threshold, there's no notification to be sent.

[00:11:34] Speaker 00:
And furthermore, John, to the extent that it teaches any threshold with its minimum cost analysis, that is a user-to-user relevancy determination.

[00:11:44] Speaker 00:
It's looking at the fashion preferences of two different users and comparing them

[00:11:48] Speaker 00:
using that as a boundary for creating groups.

[00:11:51] Speaker 00:
And the claims, instead of what John does, the claims claim a user to object relevancy determination as the basis of the threshold.

[00:12:01] Speaker 00:
If there are no questions on that, I'll save my time.

[00:12:05] Speaker 00:
We have three minutes left.

[00:12:06] Speaker 00:
Thank you.

[00:12:16] Speaker 04:
Okay, you'll just have to give us a minute while we clear out the partitions.

[00:12:21] Speaker 04:
You don't need to put them back for rebuttal.

[00:13:16] Speaker 04:
All right, is it Mr. Rosilla?

[00:13:19] Speaker 01:
Yes, it is.

[00:13:20] Speaker 04:
OK.

[00:13:21] Speaker 04:
You may proceed.

[00:13:23] Speaker 01:
You may please the court.

[00:13:25] Speaker 01:
First, I want to thank the court for the opportunity to argue virtually here.

[00:13:30] Speaker 01:
I'm representing the PTO in this matter.

[00:13:33] Speaker 01:
I wanted to take the issues that were raised by Council for Google.

[00:13:42] Speaker 01:
First, I want to point the court to

[00:13:46] Speaker 01:
Appendix 7 and Appendix 9, these are the two places where the board found that they were not persuaded of examiner error because the appellate does nothing to call into question the specific underlying factual findings made by the examiner and the evidentiary support therefor.

[00:14:04] Speaker 01:
The courts used similar language at the top of Appendix page 9.

[00:14:09] Speaker 01:
So the court, so, countable, believable, and incorrect, the board did find

[00:14:14] Speaker 01:
that Council for Google did not properly and sufficiently raise the arguments to challenge the claim efficient case made by the examiners.

[00:14:26] Speaker 01:
Second, I would say for the particular language that Council for Google just pointed this court to on pages 543 and 568, again, all that language is in the plural, talking about users in the plural.

[00:14:42] Speaker 01:
about an individual single user in those arguments.

[00:14:47] Speaker 01:
So it's not up to the board to try and figure out that they are making a different argument than the one that they actually made before the board.

[00:14:55] Speaker 01:
So I think that the board was correct to find that they didn't raise that argument.

[00:15:05] Speaker 01:
And again, going into the specifications court asked whether there was any

[00:15:11] Speaker 01:
support of the specification to somehow individualize the one or more user language in the claims.

[00:15:20] Speaker 01:
And I would say first, the claims are pretty clear.

[00:15:23] Speaker 01:
It's one or more.

[00:15:25] Speaker 01:
It's not talking about any individual user.

[00:15:28] Speaker 01:
And if you look at paragraph 33, which is on appendix page 185,

[00:15:36] Speaker 01:
The first sentence of that paragraph says that the current trend applies to one or more of the group of users.

[00:15:44] Speaker 01:
And then the language that council pointed to in paragraph 35 simply says the second to last sentence in paragraph 35 says the value may further be based on how relevant the trend is to an identified user.

[00:15:58] Speaker 01:
So that's permissive broad language that in no way would limit the claims in a way that

[00:16:23] Speaker 01:
with respect to the predetermined threshold argument.

[00:16:28] Speaker 03:
Did you want to address the limitation determining for each user of the predetermined group of users?

[00:16:38] Speaker 01:
Sure, I think it would be helpful to

[00:16:50] Speaker 01:
I think that's a good summary of Steve Axe's broad teaching and a good framework to guide the response to Google's arguments.

[00:17:07] Speaker 01:
So here, this figure four, which was cited by the examiner in the final rejection and in the examiner's answer, was also referred to by the board in appendix five

[00:17:20] Speaker 01:
This chart lays out the configuration settings that the various modules, the various software modules within Spvec can accomplish.

[00:17:33] Speaker 01:
And here it talks about, in the first block, block 454, it talks about the message that was being posted by a group of users, and that group of users, their relevance is determined

[00:17:50] Speaker 01:
by various attributes.

[00:17:52] Speaker 01:
So if you look at the list of various characteristics, the second to last one is, for example, people who have some attribute.

[00:18:03] Speaker 01:
So what it's telling you is that taking this group of users who have some attribute, and we know from paragraph 113 of Speed Act, which the examiner cites to, that one of those attributes is the interest and relevance of those users to specific topics.

[00:18:20] Speaker 01:
So in order to find the information, or in order to define the group as one that has interest and relevance to a specific topic, it's got to go through each one of those users and compare the relevance value to the user interest profile of those users.

[00:18:38] Speaker 01:
And so what happens here, what this is showing, and this is what the examiner is arguing at the end of page, appendix 559 in his answer, that the

[00:18:50] Speaker 01:
System is doing an individualized, it's checking the relevance, determining the relevance for a predetermined group of users for each one of them.

[00:18:59] Speaker 01:
And once it says that they all have some level of interest or relevance to the topic, then they will take a look and see what's going on with the messages and content that they're posting.

[00:19:10] Speaker 01:
And within that, with messaging contents they're looking at, they can find trending information.

[00:19:16] Speaker 01:
You can see that in box 456.

[00:19:19] Speaker 01:
which is the popularity and activity entries there.

[00:19:24] Speaker 01:
That shows trending information.

[00:19:26] Speaker 01:
And then we know that the scoring engine will do a, can do an individualized determination of the relevance to each user.

[00:19:37] Speaker 01:
And we can see that here in the importance to me and the relevance to me entries in box 456.

[00:19:44] Speaker 01:
And this corresponds to paragraph 115

[00:19:49] Speaker 01:
which is one of the paragraphs that the examiner cites to and that the board relies on to show how the note display, which is one of the outputs in box 458.

[00:20:01] Speaker 03:
Which paragraph was that again?

[00:20:03] Speaker 03:
I'm sorry, I missed your paragraph reference.

[00:20:05] Speaker 01:
Sure, it's paragraph 115.

[00:20:07] Speaker 01:
115.

[00:20:07] Speaker 01:
And the outputs, the notifications are shown in box 458 of Figure 4C.

[00:20:16] Speaker 01:
So I've moved down to the final box.

[00:20:18] Speaker 01:
in Figure 4C.

[00:20:21] Speaker 01:
In Paragraph 115, the examiner explains that the node display can show the relevance information in a way that, or sort of can show trending information in a way that shows what the relevance is to an individual user by changing the colors of the lines and of the nodes, and it does it continuously and keeps it updated

[00:20:46] Speaker 01:
And in that way, it does the individualized analysis and comparison of the relevance to each user and to a particular user.

[00:20:59] Speaker 01:
And we know that that information, because it's output in that notative display, that it can be the basis of the notification.

[00:21:09] Speaker 01:
And so that notification can provide information

[00:21:14] Speaker 01:
that indicates the current trend applies to one or more users of the predetermined group of users whose level of relevancy satisfies the predetermined threshold.

[00:21:23] Speaker 01:
And so, again, by stepping through each one of these boxes, the examiner, each one of the paragraph that we play to, particularly on the examiner's answer pages, page 559 and 516 and 517 of the final rejection,

[00:21:43] Speaker 01:
explains how Speed Act teaches that aspect of the climate change.

[00:21:51] Speaker 01:
And I appreciate that.

[00:21:52] Speaker 01:
That was a lot of information coming in.

[00:21:55] Speaker 01:
So if you have any questions about that.

[00:22:01] Speaker 01:
Thank you.

[00:22:02] Speaker 01:
So I think that the examiner provided the prime location case here.

[00:22:13] Speaker 01:
determination of relevancy for both the group of individuals that's defining the universe of users whose posts are being reviewed for trending information, and can also then go within each one of those individually and say, okay, the interest or relevance to me, to a particular user in that second box, can be something that causes an action.

[00:22:42] Speaker 01:
and that action in the last box are these notifications.

[00:22:44] Speaker 01:
Both the node display, which in this case is represented by the language, show me the message in a particular view or stream, or in the desktop alert, which is one of the examples that is a little further down in that list.

[00:22:59] Speaker 01:
So I think the board agreed with the examiner, cited that language in the board's opinion, and so I think

[00:23:09] Speaker 01:
both the board and the examiner here provided substantial argument on the record to show that Speed Act teaches this aspect of point one.

[00:23:20] Speaker 01:
Within the Zhang reference, talking about the predetermined threshold, Council for Google argues that it can't be considered a notification because it's a user-to-user analysis and comparison and grouping, but that's not the case.

[00:23:39] Speaker 01:
that yes, at some level it does a user-user comparison, but that comparison is based on similarity values that are based on the fashion preferences of the users to specific objects, to specific types of clothing.

[00:23:58] Speaker 01:
And so that information, those fashion preferences are the basis for the similarity determinations.

[00:24:05] Speaker 01:
And the similarity determinations in turn

[00:24:12] Speaker 01:
So the clustering that you get is ultimately based on the user's relationship with the clothing within those, with those objects.

[00:24:20] Speaker 01:
Again, if you look at the arguments made to the board, they don't challenge that.

[00:24:27] Speaker 01:
They just say that they disagree, but they don't provide any reason why the examiner's understanding and reading of that priority is not reasonable.

[00:24:37] Speaker 01:
And with respect to

[00:24:41] Speaker 01:
paragraph 64 of Zhang, which is on page, how is that?

[00:24:51] Speaker 01:
Appendix 69.

[00:24:58] Speaker 01:
This is what the board and the examiner live on to show that Zhang keeps the issuance of a notification when the threshold is met.

[00:25:10] Speaker ?:
So here,

[00:25:11] Speaker 01:
It teaches that the fashion preference cluster, which again is based on the user to object relationship and preferences, can correspond to fashion trends.

[00:25:24] Speaker 01:
And when this is the case, the system can automatically alert marketers to emerging segments.

[00:25:30] Speaker 01:
So this paragraph provides the relationship between the notification and the determination and the threshold

[00:25:46] Speaker 01:
to group and cluster the users together based on the similarity preferences, which in turn are based on their fashion preferences.

[00:25:56] Speaker 01:
And I think that's a little bit of a red herring.

[00:26:01] Speaker 01:
The court doesn't need to go that far in its analysis because the board and the examiner relied upon the schema disclosure of the relevance value

[00:26:17] Speaker 01:
Again, you can see that in Figure 4C, this relevance to me, importance to me analysis to provide the notification, that action that's done in the final box, box 458 of Figure 4C.

[00:26:35] Speaker 01:
So there is the connection between the relevance, the median, the use of relevance to send out a notification, and then they look to say,

[00:26:47] Speaker 01:
to teach the specific use of a freshly, in this case, the minimum cost threshold to send that notification.

[00:26:56] Speaker 01:
So I submit to the court that the record includes the fatal evidence to support

[00:27:15] Speaker 04:
OK, thank you.

[00:27:16] Speaker 04:
We'll hear from Ms.

[00:27:19] Speaker 04:
Curtis with respect to rebuttal.

[00:27:37] Speaker 02:
It's OK.

[00:27:51] Speaker 00:
I'll start with the last point that the Director's Council made with Zhang.

[00:27:59] Speaker 00:
The threshold at issue is not just any threshold.

[00:28:06] Speaker 00:
It is a specifically claimed threshold that is triggered by satisfying, or the notification is triggered by satisfying that threshold.

[00:28:17] Speaker 00:
It's not the case that any old

[00:28:19] Speaker 00:
threshold is going to satisfy the claim limitations.

[00:28:23] Speaker 00:
And then with respect to counsel's other point about Zhang's user to user, relevancy determinations actually being underlyingly based on user to object relevancy determinations.

[00:28:39] Speaker 00:
Zhang doesn't say anywhere that there's any sort of determination being made between the relevance of an object and the relevance to that particular user.

[00:28:49] Speaker 00:
Yes, the user's fashion preferences are going to be related to the particular objects that that person is wearing, but there's no analysis of how relevant that object is to that particular person.

[00:29:02] Speaker 00:
And especially so, any sort of analysis to that effect is not what is the input for that minimum cost analysis.

[00:29:10] Speaker 00:
That is based on similarity between fashion preferences of two users and is not the claimed user to object relevancy.

[00:29:19] Speaker 00:
determination.

[00:29:21] Speaker 00:
I'll go back to Council's first point about what the Board actually found here.

[00:29:28] Speaker 00:
Council argued that the Board found waiver over the arguments that Google is making here on appeal.

[00:29:35] Speaker 00:
The Board did no such thing.

[00:29:36] Speaker 00:
It never specifically mentioned that individualized relevancy determination for the notification.

[00:29:45] Speaker 00:
It never mentioned any of the elements of Zhang.

[00:29:48] Speaker 00:
In fact, the Board's

[00:29:49] Speaker 00:
Analysis of Zhang was was really one sentence and essentially said we don't We don't buy Google's argument and that was really the extent of the analysis there.

[00:30:00] Speaker 04:
I mean the board was saying that that That Google did not overcome the examiner's grounds for rejection Yes, but the board never analyzed what those grounds even were with respect to Zhang

[00:30:15] Speaker 00:
And I will note that the board did make a particular waiver finding about a different limitation about determining the popularity of an identified object and specifically noted that that had been waived.

[00:30:28] Speaker 00:
There was no similar analysis or argument for waiver on either of the arguments that Google has raised here on appeal.

[00:30:39] Speaker 00:
And then I'll just end with some comments about SPVAC and that figure 4C.

[00:30:46] Speaker 00:
Everything that council was talking about is an input for filtering content for users.

[00:30:54] Speaker 00:
There's no trend analysis going on.

[00:30:56] Speaker 00:
There's no application of that trend to a user.

[00:30:59] Speaker 00:
There's no notification that a particular trend does in fact apply to an individual user.

[00:31:06] Speaker 00:
All of that information

[00:31:08] Speaker 00:
that is mentioned in Figure 4C is simply to figure out what content am I going to show to a user.

[00:31:15] Speaker 00:
And there's just simply nothing in the reference that meets the claim limitations.

[00:31:22] Speaker 00:
And if there are no further questions, I will respectfully request the court reverse the board's decision.

[00:31:27] Speaker 00:
Thank you.

[00:31:27] Speaker 00:
Thank you.

[00:31:28] Speaker 00:
The cases will be submitted.

[00:31:29] Speaker 00:
The court is adjourned.