[00:00:01] Speaker 03:
The next case of argument is 21-1-0-0-5, Com Software versus NetApp.

[00:00:08] Speaker 03:
Mr. Farnham, whenever you're ready.

[00:00:14] Speaker 02:
In these cases, before Ronish, we found ability in light of combination of stick drafting canon or book and staff in the process.

[00:00:24] Speaker ?:
But I didn't correctly determine that book and staff did not disclose

[00:00:28] Speaker ?:
the only dependent claims related to access of natural files.

[00:00:36] Speaker 02:
The primary issue here is that the part of art that you pick up in Canon, these are not operating on files related to file systems.

[00:00:49] Speaker 02:
These are arts that are essentially applications.

[00:00:52] Speaker 02:
They're unaware.

[00:00:54] Speaker 02:
In order to access them, you have to go through an API

[00:00:58] Speaker 02:
It acts as a good thing to any of the underlying files.

[00:01:02] Speaker 02:
Therefore, it's not independent of the applications that you're requesting it.

[00:01:08] Speaker 02:
So one example you can think of, you know, you could, for example, any file that it can, tends to be an aggregated file of files and sizes.

[00:01:18] Speaker 02:
If you went to Linux Explorer and started looking at Canon, you can see those individual files anymore.

[00:01:22] Speaker 02:
They're no longer part of the file system, they're instead a separate system that Canon has.

[00:01:26] Speaker 02:
Sixthly, they're the same thing.

[00:01:28] Speaker 02:
provides a client-server architecture and is stored in 12 separately.

[00:01:34] Speaker 02:
Both pieces of prior art are indistinguishable from the art that the examiner found when he planned issues over a particular table.

[00:01:44] Speaker 02:
When the examiner was doing so, he noted that, finding that

[00:01:59] Speaker 02:
Those are the applications that provides the middleware in between are not independent of the location and not independent of the requesting application.

[00:02:16] Speaker 03:
Well, Mr. Finer, time is short.

[00:02:18] Speaker 03:
So maybe I'm confusing this with another case.

[00:02:20] Speaker 03:
There are a lot of IPRs going on here.

[00:02:23] Speaker 03:
So it was 1005, didn't you?

[00:02:24] Speaker 03:
1005.

[00:02:25] Speaker 03:
I thought the central issue here on appeal was the board's construction of transparent access.

[00:02:33] Speaker 02:
Yes, it is.

[00:02:34] Speaker 02:
I'll go back to that now.

[00:02:36] Speaker 02:
OK, and that's CITTA, right?

[00:02:38] Speaker 02:
I'm sorry.

[00:02:39] Speaker 03:
And the main reference here is CITTA, right?

[00:02:42] Speaker 03:
Yes.

[00:02:43] Speaker 03:
OK.

[00:02:44] Speaker 03:
And my understanding is that you were arguing that you were construing transparent access to mean that the user has to think the file is somewhere other than where it is.

[00:02:56] Speaker 03:
Is that a correct characterization of your construction?

[00:02:59] Speaker 03:
And if so, what is the basis for getting us there?

[00:03:05] Speaker 02:
So the specification makes it clear that transparent access means that the user

[00:03:12] Speaker 02:
think that the file has a particular location in it, a particular directory.

[00:03:19] Speaker 02:
And if those files get moved, that access is invisible to the user, to the application.

[00:03:26] Speaker 02:
It means it's also independent of the application, which is what I was just discussing.

[00:03:31] Speaker 03:
So it's interesting.

[00:03:32] Speaker 03:
Where is it in the specification that it matters what the user knows?

[00:03:41] Speaker 02:
I think it speaks in terms of that.

[00:03:43] Speaker 02:
I think what the specification says, and this is at 8x90.54961, it talks about how it shows the file to have any particular location.

[00:03:59] Speaker 02:
So that allows the user of the application to access that wherever it is accessed for.

[00:04:14] Speaker 02:
Can you explain what is missing in Sitka as to the transparent access limitation?

[00:04:42] Speaker 00:
As I understand it, the user doesn't know where the file is actually located when it makes the request to access the file, right?

[00:04:53] Speaker 00:
In Sitka.

[00:04:55] Speaker 02:
In Sitka, the user knows that the file is located within Sitka's system.

[00:05:04] Speaker 02:
And Sitka's server obviously knows where that file is located.

[00:05:08] Speaker 02:
They have an application that certainly knows where it is.

[00:05:12] Speaker 00:
So can you just explain why does Sitka's disclosure fail to match up with the transparent access limitation?

[00:05:26] Speaker 00:
Assume for the moment, I think Sitka meets the limitation.

[00:05:29] Speaker 00:
Why am I wrong?

[00:05:34] Speaker 02:
So the transparent access limitation, and that's how I just got some basics.

[00:05:38] Speaker 02:
Not to mean about that.

[00:05:39] Speaker 02:
It has to be.

[00:05:41] Speaker 02:
that activists also be independent of the application that's requested.

[00:05:47] Speaker 02:
And I think that is sort of the key aspect here that would say, and it's different.

[00:05:54] Speaker 02:
And those three things I was saying, the way they operate, they operate just like the Gable priority reference that examiner issues claims.

[00:06:09] Speaker 01:
And do I understand that this is your point about the APIs?

[00:06:14] Speaker 01:
Is that, or is that, or am I mistaking what you just said for?

[00:06:18] Speaker 02:
Well, I mean, that's the point about the APIs, Your Honor.

[00:06:24] Speaker 02:
The APIs mean that it's not actually, and it kind of depends on how the board read it.

[00:06:29] Speaker 02:
Again, I'll give you an example of, you know, people who went into Explorer, you know, like that file, you know, because it had the API connecting to certain systems, chat systems, any of those kind of systems.

[00:06:39] Speaker 02:
The only way you can access those in your application is that you can connect basically through those APIs.

[00:06:46] Speaker 02:
It's not like the API sits in like a file system.

[00:06:49] Speaker 02:
So you can go and buy the file system.

[00:06:51] Speaker 02:
Again, buy the file system that's just generally accessible.

[00:07:06] Speaker 02:
So the other issue, if there are

[00:07:09] Speaker 02:
Further questions on that one?

[00:07:12] Speaker 02:
I'd like to talk about the SuccessiveStorage.org claim.

[00:07:19] Speaker ?:
It's 46 and 54.

[00:07:21] Speaker ?:
In those claims, the board found that CICTA taught SuccessiveStorage to the last storage media user as an archive.

[00:07:30] Speaker ?:
Because it's not a key step.

[00:07:32] Speaker ?:
Because it teaches SuccessiveStorage, but it's not an archive.

[00:07:36] Speaker ?:
And the board's decision

[00:07:38] Speaker 02:
It's claimed to mean storage of the file storage, meaning reading to the word hard drive.

[00:07:46] Speaker 02:
And if you look at NetApp's response brief here, they pointed to the length of VINCICRA that said, well, it's below its level.

[00:07:55] Speaker ?:
They then importantly pointed to saying it's essentially a serial record of everything.

[00:08:00] Speaker 02:
It's not even a VINCICRA, but it's not about store two, which is a storage that people are relied on.

[00:08:06] Speaker 02:
That language is Store 3, which is the backup.

[00:08:10] Speaker 02:
When you go through Sitka's backup storage, which is written to you right away, it's not part of that chain, is where things like, you know, you were paying deleted files, you were paying versioned files.

[00:08:22] Speaker 00:
In Sitka, isn't both Store 2 and Store 3 at the lowest level?

[00:08:32] Speaker 02:
The next thing to describe it that way, but at the lowest level doesn't mean archive.

[00:08:36] Speaker 02:
At the lowest level means, no, at the lowest level means the last store is changed.

[00:08:43] Speaker 00:
And you're telling us, though, that store three is an archive, right?

[00:08:49] Speaker 02:
That's what SIGMA says.

[00:08:50] Speaker 02:
SIGMA is very specific about this.

[00:08:52] Speaker 02:
And now that was a brief misquote of what SIGMA says.

[00:08:56] Speaker 02:
They said that the board found and SIGMA said that that was store two.

[00:09:00] Speaker 00:
Why can't store two also be an archive if store three is, in your view, described as an archive and store three is at the lowest level?

[00:09:09] Speaker 00:
And if store two is also at the lowest level, why can't store two likewise be an archive?

[00:09:18] Speaker 02:
So you're asking if it's going to make a system that have, I don't know if you have two archives in the system, but then how would it be described?

[00:09:27] Speaker 02:
Right?

[00:09:28] Speaker 02:
Can you imagine that?

[00:09:29] Speaker 02:
I don't see that that's, because that book, I'm going to take everything right away.

[00:09:36] Speaker 02:
I'm going to stick it in the archive that's done here in Store 3.

[00:09:38] Speaker 02:
That's for that.

[00:09:39] Speaker 02:
That's where I think I started a record.

[00:09:41] Speaker 02:
That is where it gives examples of code.

[00:09:44] Speaker 02:
So for Store 2, it says you can't migrate from it, copy from it.

[00:09:57] Speaker 02:
And there was no finding by the board here that any of those features were done as 4-2.

[00:10:08] Speaker 02:
As soon as that is at the lowest level.

[00:10:11] Speaker 02:
But that's not the same thing as saying it's not right.

[00:10:24] Speaker 03:
If, let me just follow up with that sort of housekeeping question, which is we've got two IPRs involved in this appeal.

[00:10:31] Speaker 03:
And if we were to hypothetically affirm on SIPCA, does that move, my understanding is that would move Bleak & Staff, the appeal and the cross-appeal in that case.

[00:10:42] Speaker 03:
Is that your understanding of how these play together?

[00:10:46] Speaker 02:
Well, so on Bleak & Staff, the order is bound in our favor, correct?

[00:10:52] Speaker 03:
Well, on certain claims.

[00:10:54] Speaker 02:
On these, right?

[00:10:56] Speaker 02:
Yes, certain of them.

[00:11:01] Speaker 02:
On 76, that's a trend.

[00:11:02] Speaker 03:
Yes, 46 to 48, 52 to 54.

[00:11:05] Speaker 03:
But those went down in the Sitka IPR.

[00:11:08] Speaker 03:
So if we were to affirm Sitka, my read is that it would moot out

[00:11:15] Speaker 03:
your appeal in Bleak & Staff in the 603 IPR, as well as the cross appeal that the other side is arguing with respect to those claims.

[00:11:25] Speaker 02:
Yes.

[00:11:28] Speaker 03:
Thank you.

[00:11:30] Speaker 03:
You want to reserve the meeting during time?

[00:11:34] Speaker 03:
Thank you.

[00:11:36] Speaker 03:
Ms.

[00:11:36] Speaker 03:
Arner, whenever you're ready.

[00:11:39] Speaker ?:
Thank you.

[00:11:39] Speaker 05:
Good morning.

[00:11:43] Speaker 05:
May it please the court?

[00:11:45] Speaker 05:
There are really only two issues that need to be decided in order to resolve this appeal by affirming the Sitka IPR, which to your question, Judge Post, would move the Blickenstaff issues raised both in the appeal and the cross-appeal.

[00:11:59] Speaker 05:
The two issues in play are transparent access, claim construction, and with respect to the Sitka IPR, whether Store 2 in Sitka was properly mapped by the board to the last storage medium in that subset of claims.

[00:12:13] Speaker 01:
Just to be clear, do you include in your first point this question, that last clause about independent application requesting?

[00:12:24] Speaker 05:
Yes, yeah.

[00:12:25] Speaker 05:
So in the SIDCA IPR, the patent owner at the board only disputed one claim element.

[00:12:31] Speaker 05:
The final written decision kind of walks through all of the elements in the claims and notes that they only disputed that final claim element 1G, the transparent access.

[00:12:41] Speaker 05:
And transparent access claim limitation includes really four things, which are including the one that you're asking about, Judge Tronto.

[00:12:50] Speaker 05:
The first and the one that mainly was disputed is the actual meaning of transparent access, that word itself.

[00:12:56] Speaker 05:
And then the rest of that clause includes

[00:12:58] Speaker 05:
based on lifecycle access, based on lifecycle policies, regardless of where the file is located, and independently of the requesting application.

[00:13:07] Speaker 05:
And you're right, Judge Toronto, that that independently of the requesting application is the one that you discussed with Mr. Farnham.

[00:13:13] Speaker 05:
And that's the one that Com has argued is not taught because Sitka uses Appies, the application programming interface.

[00:13:20] Speaker 01:
Would you mind addressing that last piece and just explain the way the APIs or Appies work in Sitka and why that arrangement does teach this element?

[00:13:35] Speaker 05:
Independent access, sure.

[00:13:37] Speaker 05:
Yes, and I find it most useful to look at Sitka Figure 1, which is at Appendix 741.

[00:13:43] Speaker 05:
which the board relied on heavily and shows how the SIPCA system operates and why it meets all of those requirements.

[00:13:54] Speaker 05:
In figure one, the user application is what is going to request the files.

[00:13:59] Speaker 05:
And SIPCA explains that in the DSM client library, there are these APIs, among other things, that are used to translate the user application's request for a file, however they do that, into a call to the server.

[00:14:14] Speaker 05:
the DSM server, which is in the middle.

[00:14:16] Speaker 05:
And therefore when the calls get to the DSM server, the server does not know where they came from, which application they came from, because they've been translated by those APIs, the interfaces that are part of that client library.

[00:14:33] Speaker 05:
Tom did argue, I think, their primary argument against that is that they argue that the APIs are actually part of the application, that they're in the user application and not the client library.

[00:14:46] Speaker 05:
But the board rejected that argument based on a couple different pieces of evidence that support the board's mapping.

[00:14:54] Speaker 05:
One was in Dr. Long's paragraph 90 explains what I just said, basically, that the DSM server

[00:15:02] Speaker 05:
does not know where the user request comes from because of that translation that's done by the APIs in the client library.

[00:15:10] Speaker 05:
And in response to the argument from the patent owner that the APIs are part of the application, the board looks specifically at language in CITCA at column 9, 24 to 36, and some extrinsic evidence, the IEEE dictionary,

[00:15:27] Speaker 05:
that petitioners provided that defined APPEs.

[00:15:31] Speaker 05:
And the board relied on those pieces of evidence to support its conclusion that the APPEs are separate from the applications.

[00:15:40] Speaker 05:
And they're part of, as Sitka describes, that DSM client library.

[00:15:44] Speaker 05:
And that's why the access in Sitka is independent of whatever application did the requesting.

[00:15:52] Speaker 05:
The other pieces of that transparent access mapping in Sitka, regardless of where the file is located, that's done in that figure two because DSM server is the functionality that moves the files through the backup storage on the right-hand side of that figure one.

[00:16:10] Speaker 05:
And it does it according to migration rules that are stored in the database server.

[00:16:15] Speaker 05:
So all of the movement of the files is happening on the right side, the server side there.

[00:16:20] Speaker 05:
according to the rules in the database server.

[00:16:23] Speaker 05:
And therefore, the client does not need to know where it is, regardless of where the file is located.

[00:16:28] Speaker 05:
The DSM server is what does, in CITCA, that translation between the file that's been requested, it goes and looks up the location of the file, which is in that database server, and then pulls the file.

[00:16:41] Speaker 05:
So that's why it is, regardless of where the file is located,

[00:16:45] Speaker 05:
Com did not dispute the based on life cycle policies part of the claim element in Sitka.

[00:16:51] Speaker 00:
Getting back to independently, what do you think is the point of that last clause in the final limitation of providing transparent access independently of said application requesting access?

[00:17:05] Speaker 00:
What is the point of that?

[00:17:09] Speaker 00:
I don't understand the relevance of that limitation.

[00:17:11] Speaker 05:
I think they were trying to get to the same place that many of the prior art references are getting.

[00:17:16] Speaker 05:
Like in Blitkensteft, it describes a hierarchical storage system that is completely transparent to both the server and the requester.

[00:17:23] Speaker 05:
It does its own thing automatically, essentially, and decides, based on rules that are pre-configured, how to move the files.

[00:17:30] Speaker 05:
And that can be done based on age, which is one of the primary parameters that's described.

[00:17:36] Speaker 05:
And that's where, I think, where they're trying to get.

[00:17:38] Speaker 05:
So the independent of the requesting application is meaning that the system doesn't know about the requester.

[00:17:44] Speaker 05:
And the regardless of where the file is located means that the requester doesn't need to know about where it is located.

[00:17:50] Speaker 05:
The server takes care of that.

[00:17:52] Speaker 05:
And that's why Sitka is so good on these claims because it has the server

[00:17:56] Speaker 05:
the DSM server and the DSM client providing those two pieces of the functionality.

[00:18:05] Speaker 05:
So they didn't dispute the based on lifecycle policies, that third part of the claims.

[00:18:10] Speaker 05:
So really, the only other dispute is the meaning of the word transparent.

[00:18:14] Speaker 05:
And as you noted, Judge Prost, below, the patent owner argued for a mistaken belief or the fiction that the user has to think it's one place and not have it be there.

[00:18:25] Speaker 05:
But the board properly rejected that.

[00:18:27] Speaker 05:
And really, for the claim construction here, I think this is the clearest case I've ever seen of a prosecution history answering the issue.

[00:18:34] Speaker 05:
The patent owner's construction, although it has evolved and changed, both below and even here on appeal, they do tend to look at that passage in column five of the patent.

[00:18:44] Speaker 05:
where it says, as far as a user is concerned, the file is in a particular location on a particular drive.

[00:18:49] Speaker 05:
That's the only use of the word transparent in the patent.

[00:18:52] Speaker 05:
And the board looked at that and said, well, it uses the permissive may, not a must, so it's not limiting.

[00:18:57] Speaker 05:
But the claim transparent access may include that example, but it's not limited to it.

[00:19:02] Speaker 05:
And really, the answer came for the board in the prosecution history.

[00:19:06] Speaker 05:
That phrase was added to the claims during prosecution.

[00:19:10] Speaker 05:
And when it was added, the applicant

[00:19:12] Speaker 05:
both when explaining the invention to the examiner, and then later, when distinguishing the prior art, said that transparent access means that the user does not have to know where the file is located physically in order to access it.

[00:19:25] Speaker 05:
And looking at those very plain statements in the prosecution history, the board supported its construction and rejected COM's attempt to require user knowledge, whether right or wrong.

[00:19:36] Speaker 05:
The board also looked properly at the extrinsic evidence that COM provided and found that it supported the board's construction because it said that there is no single standard way to provide transparent access.

[00:19:52] Speaker 05:
In order to affirm the SIPCA IPR, there is one other issue in addition to claim construction and that mapping that I just described, which is the successive migration claim elements and

[00:20:06] Speaker 05:
There are two parts of these claims, the additional functionality added in that subset of claims.

[00:20:13] Speaker 05:
The first is that files move from a first storage medium to a last storage medium in successive stages.

[00:20:20] Speaker 05:
And then there's also the requirement that the last storage medium be associated with archive files.

[00:20:25] Speaker 05:
And the board found substantial evidence to show that CITCA discloses both pieces of those claims.

[00:20:32] Speaker 05:
For the successive stages, the board looked at long paragraph 99 in his declaration, where he explained that the way that Sitka described short-term storage and long-term storage would indicate or convey to a skilled artisan that the files move in stages in Sitka.

[00:20:50] Speaker 05:
And more specifically, he also gave in his paragraphs 101 and 102 a specific example in Sitka.

[00:20:58] Speaker 05:
where the files move from store 0 to store 1 to store 2.

[00:21:03] Speaker 05:
So those pieces of evidence, Long at paragraphs 99, 101, and 102, were relied upon by the board to find that Sitka discloses the successive movement.

[00:21:14] Speaker 05:
And then with respect to the second requirement, which is that that last storage medium be associated with archive files, the board looked specifically at paragraph 98 of Dr. Long's declaration, where he gave multiple reasons why

[00:21:28] Speaker 05:
the Store 2 in Sitka would be associated with archive files.

[00:21:31] Speaker 05:
Not just that it was at the lowest level, although that was one of the reasons, but he also said it describes longer access times and also does not allow any further migration from Store 2.

[00:21:42] Speaker 05:
And those are all reasons why a skilled artisan would have understood that Store 2 in Sitka is associated with archive files.

[00:21:51] Speaker 05:
Because there is substantial evidence for both pieces, the board's mapping of Sitka to Store 2 in those

[00:21:57] Speaker 05:
successive migration claims should be affirmed as well.

[00:22:11] Speaker 05:
Unless there are other questions, I'll just spend one minute on our cross appeal, if I may, just to mention it.

[00:22:15] Speaker 05:
Only if the court decides to reverse on the Sitka IPR, the cross appeal relates to those same successive migration claims in the Blinkenstaff IPR.

[00:22:27] Speaker 05:
And I would just call the court's attention to the second of the reply arguments made by the petitioner, which called back specifically to the retirement layer mapping in the petition.

[00:22:40] Speaker 05:
The board spent most of its time in its final written decision on its reasons to discard the first mapping, which was to the shelf layer.

[00:22:48] Speaker 05:
But there are just two sentences on Appendix 75 that address the second argument by the petitioner, and that's the one

[00:22:55] Speaker 05:
that the board would need to consider on remand.

[00:23:00] Speaker 05:
But again, if you don't reverse on Sitka, then no remand would be needed.

[00:23:05] Speaker 05:
Thank you.

[00:23:05] Speaker 05:
Thank you.

[00:23:06] Speaker 05:
I'll reserve the rest of my time.

[00:23:08] Speaker 03:
OK, we're ready.

[00:23:10] Speaker 03:
We're ready for rebuttal, Mr. Farn.

[00:23:13] Speaker 02:
But again, Sitka and Cannon, going back to something that Councilor said, they described the ESM as being in the mail by what it is.

[00:23:24] Speaker 02:
middleware, it's an application.

[00:23:28] Speaker 02:
That's the same as cable.

[00:23:30] Speaker 02:
It's just something that the examiner expressly allows them to find it over.

[00:23:34] Speaker 02:
The way they operate the APIs, you can't, they provide a way to get you into that system.

[00:23:41] Speaker 02:
That doesn't mean everything can.

[00:23:43] Speaker 02:
It's not independent of the application.

[00:23:44] Speaker 02:
The application actually has to be able to have the API attached to it.

[00:23:48] Speaker 02:
It has to go to register with it.

[00:23:49] Speaker 02:
You can't do that with everything.

[00:23:51] Speaker 02:
So the problem with sitting in

[00:23:54] Speaker 02:
Any of these, any of the secret account, anything like that, I can't just go into Excel or Word or whatever is the right program and access that file.

[00:24:05] Speaker 02:
That's a difference from being independent.

[00:24:08] Speaker 02:
What does the term independent mean here?

[00:24:10] Speaker 02:
Independent here is if you are on there, it doesn't matter what application is trying to access you.

[00:24:16] Speaker 02:
Like any file system, that's what we explained here about files and file systems not stored in separate applications.

[00:24:24] Speaker 02:
And there was, I think it was clear on the record here and a lot of sort of how these guys were kind of not working.

[00:24:31] Speaker 02:
The basic point here is just the fact that they are there means that independent limitation is not net.

[00:24:38] Speaker 02:
Independent type does not mean simply, oh, the server doesn't know.

[00:24:42] Speaker 02:
That's more of a transparency type issue.

[00:24:45] Speaker ?:
It's all the pieces of this to keep it independent, which means it doesn't matter.

[00:24:54] Speaker 02:
The file systems on applications, these are client-directed file systems, if you look at

[00:25:20] Speaker 02:
In terms of the successful transfer issue, I don't think that the two points of migration or log access time makes no difference.

[00:25:47] Speaker 02:
And those are the things about, again, that's just redefining the last store of the medium, right?

[00:25:52] Speaker 02:
What makes an archive of things like serene deleted files, you know, the patent talks about things.

[00:25:56] Speaker 02:
What can you do to keep deleted files?

[00:25:59] Speaker 02:
You know, where does SIGMA, SIGMA talks about that too, it talks about the store three.

[00:26:03] Speaker 02:
You know, that's where they're deleted files, that's where they're versioned files.

[00:26:07] Speaker 02:
And then there wasn't much discussion.

[00:26:11] Speaker 02:
Looking to that, I think it was not abuse, or discretion, and the board is correct,

[00:26:16] Speaker 02:
and finding that there was a change in the way that they were being put down.

[00:26:21] Speaker ?:
And it's very clear that this retirement letter is not part of the resources.

[00:26:27] Speaker 03:
OK.

[00:26:30] Speaker 03:
Thank you.

[00:26:31] Speaker 03:
Nothing further?

[00:26:31] Speaker 03:
Thank you.

[00:26:39] Speaker 03:
Well, Ms.

[00:26:40] Speaker 03:
Arner, you have some time left on your cross appeal.

[00:26:42] Speaker 03:
There was really very little mention of the cross appeal in the argument, so I don't know.

[00:26:47] Speaker 05:
I would only offer to answer the questions on the cross appeal if there are any.

[00:26:50] Speaker 03:
No.

[00:26:50] Speaker 03:
Thank you very much.

[00:26:52] Speaker 03:
We thank both sides, and the case is submitted.