[00:00:00] Speaker 02:
Our argument next in number 20-1858, NEPCO drivelines LLC versus American Axle on manufacturing, Mr. Abdelnor.

[00:00:11] Speaker 01:
Good morning, and may it please the court, Dennis Abdelnor on behalf of Appellant and Patent Owner in this case, NEPCO drivelines.

[00:00:20] Speaker 01:
There are two issues we've raised on appeal.

[00:00:24] Speaker 01:
both require independent errors requiring separate relief.

[00:00:31] Speaker 01:
The first is whether the preamble is limiting.

[00:00:34] Speaker 01:
The second is whether the prior art satisfies the limitation providing a vent.

[00:00:40] Speaker 01:
Because the first one is independent and requires relief, and if the court agrees with us on that issue, it doesn't need to reach the second issue.

[00:00:50] Speaker 01:
I'm going to focus my argument

[00:00:52] Speaker 01:
today on the first issue, unless, of course, there are questions on the second.

[00:00:58] Speaker 02:
Well, I understand how the first issue can be dispositive when the board said that even if it adopted your construction of the preamble and found it limiting, it would reach the same result.

[00:01:11] Speaker 01:
Well, because what the board said there was if the preamble is limiting, it would construe the preamble in a particular way.

[00:01:20] Speaker 01:
And our argument is that this alternative construction that the board suggested, and I believe that's at appendix page 16, it is an incorrect claim construction.

[00:01:34] Speaker 01:
So the way we've framed this issue, Your Honor, is one, the board erred in finding the preamble was not limiting.

[00:01:42] Speaker 01:
And two, if the preamble is limiting, it should be given its plain and ordinary meaning.

[00:01:48] Speaker 01:
which would require venting to outside the slip joint assembly.

[00:01:53] Speaker 01:
And if those two, if the court agrees with us on both of those fronts, then there is no dispute in this case, and American Axles conceded, and their expert has conceded, that the prior Art Burton reference, which was the primary reference, the anticipatory and primary reference in the obviousness combination, doesn't satisfy the preamble.

[00:02:18] Speaker 00:
I also don't understand your suggestion that these are independent bases.

[00:02:24] Speaker 00:
I understand your Burton argument to hinge upon us adopting the claim construction you prefer.

[00:02:30] Speaker 00:
I don't understand your Burton argument as legitimately challenging the fact finding that Burton provides event as construed by the board.

[00:02:42] Speaker 01:
Okay, so let me clear that up then, Your Honor, because the

[00:02:46] Speaker 01:
The question of whether burden satisfies the providing event limitation is an application of that construction.

[00:02:53] Speaker 01:
There's no dispute as to burden, that the slip joint assembly is completely sealed.

[00:03:01] Speaker 01:
No air ever escapes to outside the slip joint assembly.

[00:03:05] Speaker 00:
Yes, but Council, the client construction event adopted by the board, it just has to escape the cavity.

[00:03:12] Speaker 00:
And in Burton, it escapes the passage that it's in.

[00:03:16] Speaker 00:
So why is that not something that we would say is supported by substantial evidence?

[00:03:23] Speaker 00:
That the board did not conclude it has to escape the entire slip joint assembly, just that it had to escape a cavity.

[00:03:32] Speaker 01:
In your honor, and the reason for that is the construction of vent was made specifically with respect to the limitation within the body of the claim providing a vent.

[00:03:42] Speaker 01:
And the argument and the reason it says a cavity there is because the body of the claim specifically points to leaving the two different cavities.

[00:03:55] Speaker 01:
Our argument as to the preamble is that the preamble says a method of venting a slip joint assembly.

[00:04:01] Speaker 00:
Yes, counsel, but this is not my question.

[00:04:03] Speaker 00:
You claim that you have two independent arguments on appeal, either one of which could entitle you to judgment in your favor.

[00:04:12] Speaker 00:
And I'm saying I don't see how you've made any argument at all about Burton that is independent from your preamble argument.

[00:04:25] Speaker 01:
Okay, well, Your Honor, page 49, I believe, of our opening brief is where we talk about the admissions that Burton doesn't vent to outside the slip-joint assembly.

[00:04:36] Speaker 01:
And so the argument on appeal, to be clear, is that the preamble requires something more and in addition to what's recited in the body of the claim.

[00:04:48] Speaker 01:
The board found that Burton satisfies the body of the claim.

[00:04:52] Speaker 01:
So for purposes of the preamble arguments,

[00:04:54] Speaker 01:
Assume that to be true.

[00:04:57] Speaker 01:
But at page 49 of our brief, we point out that even if Burton satisfies the providing event limitation, even if Burton satisfies the body of the claim, it does not satisfy the preamble.

[00:05:10] Speaker 01:
And the only way the board found anticipation was explicitly finding that the preamble didn't limit in this case.

[00:05:20] Speaker 01:
And the board erred in finding the preamble didn't limit because

[00:05:25] Speaker 01:
It misidentified the invention in the patent.

[00:05:29] Speaker 01:
We know that the patent is not concerned with sealed slip joint assemblies.

[00:05:34] Speaker 01:
The invention is a specific improvement, and it is an improvement only to vented slip joint assemblies.

[00:05:43] Speaker 01:
Looking at the problem in the prior art that the 520 patent identifies, the problem

[00:05:51] Speaker 01:
And it uses Cook Junior as an example.

[00:05:54] Speaker 01:
Cook Junior is a vented slip joint assembly, where there is venting to outside the slip joint assembly.

[00:06:00] Speaker 01:
The problem with Cook Junior identified by the 520 is it allows for the ingress of contaminants at the lubricant zone.

[00:06:09] Speaker 01:
And so the inventor said, we want to keep the venting.

[00:06:12] Speaker 01:
We want that reduced resistance from venting.

[00:06:15] Speaker 01:
But we want to get rid of the problem of contamination.

[00:06:18] Speaker 01:
And so what they did was they moved the location of the vent to the opposite end of the slip joint assembly, wherein they were able to keep the benefits of venting, which is reduced resistance against slip.

[00:06:30] Speaker 01:
But they eliminate or minimize the problem of contamination entering into the slip joint lubricant zone.

[00:06:39] Speaker 01:
This problem doesn't exist in the context of a sealed slip joint assembly, such as in Burton.

[00:06:46] Speaker 01:
And Cook Jr., for example, actually discloses an alternative body.

[00:06:52] Speaker 02:
It's the case, is it not, that in the primary embodiment in your patent, as well as in Burton, it's a sealed assembly.

[00:07:01] Speaker 02:
It's not vented to the outside air, right?

[00:07:05] Speaker 01:
That's not correct, Your Honor.

[00:07:07] Speaker 01:
Let me explain.

[00:07:08] Speaker 01:
In our patents,

[00:07:11] Speaker 01:
air escapes outside the opposite end of the slip joint and it escapes into the hollow drive shaft tube.

[00:07:17] Speaker 01:
Every expert and everybody in this case agrees that's outside of the slip joint assembly.

[00:07:22] Speaker 02:
I understand that, but it's not vented to the outside air.

[00:07:26] Speaker 02:
That's only presented in the patent as an alternative embodiment.

[00:07:30] Speaker 02:
The primary embodiment is a sealed assembly in which the air moves from one chamber to another.

[00:07:37] Speaker 02:
And that's true in Burton as well, right?

[00:07:41] Speaker 01:
Again, Your Honor, respectfully, let me disagree and explain.

[00:07:47] Speaker 01:
The air escapes the slip joint assembly into the hollow drive shaft.

[00:07:51] Speaker 01:
The hollow drive shaft is not a part of the slip joint assembly.

[00:07:55] Speaker 01:
It's a different component.

[00:07:57] Speaker 02:
But that wasn't my question.

[00:07:58] Speaker 02:
My question was that in Burton and in your patent, they both involve field systems in which the air vents from one chamber to another.

[00:08:08] Speaker 02:
And your argument, and your only argument, if I understand it,

[00:08:12] Speaker 02:
is that Burton is different because in Burton, it's venting within the slip joint assembly, whereas in your patent, it's venting to another portion of the assembly.

[00:08:26] Speaker 02:
Is that correct?

[00:08:29] Speaker 01:
It's not correct.

[00:08:30] Speaker 01:
And the reason I'm disagreeing, Your Honor, is because where it is venting to in the 520 patent is indisputably outside the slip joint assembly.

[00:08:40] Speaker 01:
In Burton,

[00:08:42] Speaker 01:
There is a, there is a, the end of the male shaft has a cap on it and it's welded to it.

[00:08:48] Speaker 01:
That keeps everything within the slip joint assembly.

[00:08:51] Speaker 01:
And so I guess my disagreement is over the system.

[00:08:56] Speaker 01:
I agree with you that in the 520 patent, we vent to outside the slip joint assembly.

[00:09:01] Speaker 01:
And in certain instances, it's still contained within a larger system that includes the hollow drive shaft.

[00:09:07] Speaker 01:
But the hollow drive shaft is not a part of the slip joint assembly.

[00:09:11] Speaker 01:
And the fundamental difference with Burton is that Burton has that cap welded to the end of the male shaft in the slip joint assembly, so nothing ever escapes.

[00:09:23] Speaker 01:
And what you end up having is a circulation almost like a pump system where lubrication and air is pumped back and forth between these internal chambers.

[00:09:33] Speaker 01:
And the testimony in this case is that when you vent outside the slip joint assembly,

[00:09:39] Speaker 01:
Even though it's being vented to the hollow drive shaft.

[00:09:41] Speaker 01:
The hollow drive shaft is a separate component.

[00:09:44] Speaker 01:
The size of the volume of that cavity is many times larger than the size of the cavities within the slip joint assembly.

[00:09:51] Speaker 01:
And so you do get venting.

[00:09:53] Speaker 01:
And it's a fundamental difference.

[00:09:55] Speaker 00:
I'll just judge more.

[00:09:56] Speaker 00:
But one of the important differences, it seems to me,

[00:10:02] Speaker 00:
is that in claim six of your patent, you make it clear that the venting is not just outside of the first and second cavity, but it's into the driveshaft assembly.

[00:10:14] Speaker 00:
So outside of the slip joint assembly and into the driveshaft assembly, the large two foot long driveshaft.

[00:10:22] Speaker 00:
And so that's claim six.

[00:10:24] Speaker 00:
Claim six says, where are we going to vent to?

[00:10:25] Speaker 00:
We're going to vent into the driveshaft assembly, which means completely out of the slip joint assembly.

[00:10:31] Speaker 00:
But the claimant issue here, claim 11, says you vent outside of the first and second cavity.

[00:10:37] Speaker 00:
That still leaves room for venting within the slip joint assembly itself.

[00:10:43] Speaker 00:
It distinguishes between when you would vent out of the slip joint assembly, a la claim six, from when you would vent possibly still within the slip joint assembly, claim 11.

[00:10:55] Speaker 00:
How do you deal with that?

[00:10:58] Speaker 01:
Right, Your Honor.

[00:10:59] Speaker 01:
First of all, it's not a claim differentiation question.

[00:11:03] Speaker 00:
I didn't ask you if it was a claim differentiation question, counsel.

[00:11:08] Speaker 00:
I'm telling you, you knew how to specify when you wanted the venting to go outside of the slip joint assembly, and you did so clearly in claim six.

[00:11:17] Speaker 00:
In claim 11, in contrast, you just said you wanted to vent outside the first or second cavity.

[00:11:24] Speaker 00:
Why should we import into that the broader venting outside of the whole flip joint assembly?

[00:11:33] Speaker 01:
Our position, Your Honor, is that the preamble fills in that critical missing gap.

[00:11:38] Speaker 01:
And when you do the analysis of whether the preamble limits and whether it provides necessary and important scope and context to the body of the claim,

[00:11:47] Speaker 01:
The preamble is doing that work and our position is that the fact that you see that additional information in claim 6 but it's absent from claim 11 only further supports the notion that the preamble is doing additional work here.

[00:12:02] Speaker 00:
But counsel, the preamble is virtually the same between Claim 6 and Claim 11, recognizing one is apparatus and the other is method, but they both have the vented slip-joint assembly language.

[00:12:14] Speaker 00:
So if I were to buy into what you want me to with regard to the preamble, then it seems like it would be superfluous in Claim 6.

[00:12:25] Speaker 01:
Well, Your Honor, for example, choose by

[00:12:28] Speaker 01:
and she was by fire about this court doesn't hasn't hesitated to find and different situation circumstances the same preamble can be limiting in one and not limiting in the other here we've got it but another differences the method claim versus an apparatus claim uh... it but nevertheless claimed eleven in the preamble brings the scope of these claims it back into line with what was actually invented the specific improvement to a specific vented

[00:12:58] Speaker 01:
slip-joint assembly.

[00:13:00] Speaker 01:
And without that critical information from the preamble of claim 11, the scope of these claims is broadened to where you get this contradictory situation that burden, which is indisputably a sealed slip-joint assembly, reads on the body of claim 11.

[00:13:19] Speaker 01:
And we're simply asking the court to give the plain meaning of the preamble, its limiting weight,

[00:13:25] Speaker 01:
which brings the scope of the claims into line with the actual invention disclosed and no broader.

[00:13:32] Speaker 01:
I'll reserve my remaining time.

[00:13:34] Speaker 01:
Thank you, Your Honors.

[00:13:36] Speaker 02:
All right.

[00:13:36] Speaker 02:
Mr. Capers.

[00:13:39] Speaker 03:
Good morning, Your Honor.

[00:13:40] Speaker 03:
Robert Capers on behalf of the American Actual.

[00:13:43] Speaker 03:
May it please the Court.

[00:13:45] Speaker 03:
The Court should affirm.

[00:13:47] Speaker 03:
The APCO is asking the Court to do two things that it should not be doing.

[00:13:52] Speaker 03:
The APCO first asks the Court to

[00:13:55] Speaker 03:
make the preamble of claim 11, venting a slip joint assembly, a second vent limitation, when the claim body already has a vent limitation, and when claim 6 shows that the inventors did not intend for the preamble to serve as a limitation.

[00:14:12] Speaker 03:
But then the app goes going further.

[00:14:15] Speaker 03:
And it asks this court to change the plain meaning of the preamble to require external venting outside of a slip joint.

[00:14:24] Speaker 03:
and exclude the internal venting from one cavity of the assembly to another cavity, which is supported by the intrinsic evidence in this case.

[00:14:35] Speaker 00:
So you just suggested that they want to change the meaning of the preamble.

[00:14:38] Speaker 00:
I thought your argument was that the preamble is not a limitation at all, not that they wanted to change the meaning of it.

[00:14:46] Speaker 03:
Your Honor, we've made both arguments that the preamble is not a limitation.

[00:14:51] Speaker 03:
And just as a threshold matter, it should not be construed to limit claim 11.

[00:14:55] Speaker 03:
But we made the separate argument that the preamble still covers venting one cavity of a slip joint to another cavity.

[00:15:05] Speaker 03:
It covers the type of internal venting of a slip joint.

[00:15:09] Speaker 00:
If the preamble is a limitation and it says a vented slip joint assembly,

[00:15:16] Speaker 00:
Wouldn't the plain meaning of that language mean that the air is going to vent outside the assembly, a vented flip-joint assembly?

[00:15:28] Speaker 03:
No, Your Honor.

[00:15:29] Speaker 03:
You can have internal passageways within the assembly that vent the cavities and relieve pressure, a pressure differential that exists in those cavities

[00:15:40] Speaker 00:
during operation and that's certainly... You can't actually in the context of this invention.

[00:15:45] Speaker 00:
The slip joint assembly is a minuscule device.

[00:15:48] Speaker 00:
How can you control for pressure by venting from one cavity to the other in a device of this size?

[00:15:58] Speaker 03:
Your Honor, as the male shaft, the stud yoke, plunges into the slip yoke, it's going to decrease the volume in that cavity and pressure is going to increase.

[00:16:10] Speaker 03:
And adding a vent is what relieves that pressure, and it allows the air to escape into the other cavity.

[00:16:16] Speaker 03:
And American Axles expert in this case showed how applying like basic physics, the combined gas law, showed how even adding a vent in an assembly like Burton, where air is vented from one cavity to another, equally sized cavity, still relieves pressure in that joint.

[00:16:37] Speaker 03:
And so that's, and Burton discusses this

[00:16:40] Speaker 03:
how these passages reduce resistance in that joint as a result.

[00:16:50] Speaker 03:
But as the, Your Honor, Judge Moore, you're correct.

[00:16:54] Speaker 03:
We're arguing that the preamble is first just not a limitation and the body of claim 11 already has that limitation and it's clear.

[00:17:03] Speaker 03:
It covers the escape of compressed air from a cavity to another cavity of the assembly

[00:17:10] Speaker 03:
And NIASCO is asking this question.

[00:17:13] Speaker 00:
Council, when the summary of the invention says, a vent for escape of compressed air in a manner which does not enable ingress of contaminants, is that satisfied by simply venting from one cavity to the other?

[00:17:29] Speaker 03:
Yes, Your Honor.

[00:17:34] Speaker 03:
But if we look at Burton,

[00:17:36] Speaker 03:
Burton solved the exact same problem that the 520 patent is trying to solve.

[00:17:41] Speaker 03:
It closes the system to keep contaminants out of the system and keep lubricant in.

[00:17:47] Speaker 03:
But then it adds these passageways to relieve the increase in pressure that occurs in those cavities.

[00:17:55] Speaker 03:
And it does in the same manner that the 520 patent describes, which is

[00:18:01] Speaker 03:
venting from the end of the, from the end, the opposite end of the spline, you know, where there's a cap.

[00:18:08] Speaker 03:
And so, yes, Burton does provide that type of venting described.

[00:18:14] Speaker 00:
But I understand that you're saying Burton does, but doesn't, if I construe vent, a vented slip shaft, I'm sorry, a vented slip joint system,

[00:18:27] Speaker 00:
the way that you want me to, doesn't it potentially allow contaminants?

[00:18:31] Speaker 00:
This is an unsealed system.

[00:18:34] Speaker 00:
Burton is a sealed system.

[00:18:35] Speaker 00:
There's no concern about contaminants in Burton.

[00:18:39] Speaker 00:
So this is an unsealed system.

[00:18:41] Speaker 00:
So doesn't the construction you're giving allow for contaminants to get in?

[00:18:55] Speaker 03:
It would depend on the configuration of the system, Your Honor.

[00:19:00] Speaker 03:
If the system is open to the atmosphere, yes, there would be some risk that contaminants could enter that system.

[00:19:11] Speaker 00:
Wouldn't your answer to my question be that if I give the preamble meaning, it would still cover both sealed and unsealed systems?

[00:19:24] Speaker 00:
and that Burton would therefore anticipate, may not anticipate the unsealed systems, but it would at least anticipate as to the sealed systems and that that's all you need for anticipation of any portion of the claim is anticipated.

[00:19:38] Speaker 00:
The whole thing goes down.

[00:19:39] Speaker 00:
Is that what your answer ought to be?

[00:19:42] Speaker 03:
Yes, Your Honor.

[00:19:43] Speaker 03:
That's exactly right.

[00:19:44] Speaker 03:
And, um, NYAPCO in this case and before the board has presented this false dichotomy between a

[00:19:53] Speaker 03:
sealed assembly or a closed assembly and a vented assembly.

[00:19:58] Speaker 03:
And those two concepts are just completely different.

[00:20:02] Speaker 03:
Sealing keeps the lubricant in and the contaminants out of the system.

[00:20:06] Speaker 03:
But venting is what relieves the pressure that increases in the cavity.

[00:20:11] Speaker 03:
And so you can have a sealed or a closed system that is also vented.

[00:20:15] Speaker 03:
And that is why, even if the preamble were a limitation, the preamble should still be construed to cover the type

[00:20:23] Speaker 03:
internal venting that Burton teaches.

[00:20:26] Speaker 00:
Council, what are the four exceptions?

[00:20:28] Speaker 00:
I mean, we have a general rule, preambles are not limitation, but what are the four exceptions to that rule that stem from Catalina Marketing?

[00:20:38] Speaker 03:
Let me grab my notes here, Your Honor.

[00:20:46] Speaker 03:
Yeah, Catalina provides several of these guideposts and

[00:20:52] Speaker 03:
In this case, each of those guideposts leads to the same conclusion.

[00:20:57] Speaker 03:
You know, I don't know if this core has characterized them as exceptions or not, but exceptions or not, they still lead to the same conclusion that the preamble is not limiting.

[00:21:09] Speaker 03:
For example, the claims certainly recite a structurally complete invention.

[00:21:14] Speaker 03:
There's already a vent limitation in the claim body.

[00:21:17] Speaker 03:
And Yavko has argued that the vent limitation is incomplete.

[00:21:22] Speaker 03:
simply because it doesn't identify the destination for the air that escapes.

[00:21:26] Speaker 03:
But it does because it recites outside of the first and second cavity.

[00:21:32] Speaker 03:
And that's the destination that the inventors of the 520 patent chose for claims 11 and 12 but did not choose for other claims like claim 6.

[00:21:42] Speaker 03:
And another exception, Your Honor, is focuses on the specification and whether underscores is important

[00:21:50] Speaker 03:
the structure recited in the preamble.

[00:21:53] Speaker 03:
And it's true that in the 520 patent, the final destination for the air is described as the drive shaft tube or the atmosphere.

[00:22:03] Speaker 03:
But that's not the invention of the 520 patent.

[00:22:05] Speaker 03:
It's talking about relieving pressure from the two cavities, internal bore 16 or cavity 60.

[00:22:13] Speaker 03:
And it talks about doing it in a way that vents from the opposite end of the slip yoke.

[00:22:19] Speaker 03:
And what the prior art shows, including Burton, is that you can have a closed system and do both of those things.

[00:22:33] Speaker 02:
Okay.

[00:22:33] Speaker 02:
Go ahead.

[00:22:36] Speaker 03:
No, Your Honor.

[00:22:36] Speaker 03:
I was just about to conclude.

[00:22:38] Speaker 03:
So thank you.

[00:22:40] Speaker 03:
So to conclude, the court should affirm the board's judgment that claims 11 and 12 of the 520 pass are unpackable.

[00:22:48] Speaker 03:
Thank you.

[00:22:49] Speaker 00:
Nice job, Council.

[00:22:51] Speaker 02:
Thank you, Mr. Kappers.

[00:22:52] Speaker 02:
Mr. Abdelnor?

[00:22:56] Speaker 01:
Thank you.

[00:22:57] Speaker 01:
Directly to the question of what is the meaning of the preamble in the event that it limits, it means what it says.

[00:23:06] Speaker 01:
It means what this patent says, which is venting to outside the slip joint assembly.

[00:23:10] Speaker 01:
And Judge Moore, I think you had it right when you said there is no way to do it properly within this small slip joint system and these cavities.

[00:23:19] Speaker 01:
You have to go to outside in the 5-to-0 patent.

[00:23:22] Speaker 01:
It's going to the hollow drive shaft or further to the atmosphere.

[00:23:26] Speaker 01:
And you know that it's getting the benefits of venting to outside the slip joint assembly.

[00:23:31] Speaker 01:
Looking at columns three, starting at 19 to 25, talking about how you have reduced resistance during installation and you have reduced resistance during operation.

[00:23:42] Speaker 01:
Burden is exactly the opposite, and Burden describes a vent hole

[00:23:47] Speaker 01:
In Burton, it has a vent hole that is actually plugged.

[00:23:50] Speaker 01:
The vent hole is provided to reduce resistance during installation.

[00:23:55] Speaker 01:
And it actually plugs it, and it says, well, we're going to have increased resistance during operation, but we're going to balance the different pressures on each side of the slip joint, meaning it's a fundamentally different system.

[00:24:09] Speaker 01:
The 512 is a narrow improvement to a particular type of system, a vented slip joint assembly.

[00:24:16] Speaker 01:
And the preamble and the body of the limitation, the body of the limitation, sorry, the body of the claim provides that improvement and the preamble tells you what it is improving.

[00:24:27] Speaker 01:
And in this context, this court is not hesitated to find the preambles limiting, for example, applied materials during company.

[00:24:36] Speaker 01:
In applied materials, for example, the question was, does a cold purge process in the preamble limit?

[00:24:42] Speaker 01:
And the board, this court did exactly the same analysis.

[00:24:45] Speaker 01:
It looked at the problem, the patent overcame and the invention, and it found that problem just only in the context of processes.

[00:24:55] Speaker 01:
And if I just may finish my thought and therefore, and therefore the preamble and the body of the claim go hand in glove.

[00:25:04] Speaker 01:
And they're, they're used in combination to define the scope of the claim.

[00:25:09] Speaker 01:
And again, we asked that the court find the preamble limiting.

[00:25:12] Speaker 01:
given its plain meaning.

[00:25:14] Speaker 01:
And if it does so, that's the true scope of the invention, and Burton does not anticipate.

[00:25:20] Speaker 01:
Thank you very much, Your Honors.

[00:25:21] Speaker 02:
Thank you, Mr. Elinor.

[00:25:22] Speaker 02:
Thank you, Mr. Capers.

[00:25:24] Speaker 02:
The case is submitted.