[00:00:01] Speaker 02:
Our next case on the docket is Alter One Inc.

[00:00:05] Speaker 02:
versus Unified Patents, appeal number 22-1029.

[00:00:08] Speaker 02:
Mr. Gerst, you may proceed whenever you're ready.

[00:00:33] Speaker 03:
Good morning, and may it please the court.

[00:00:36] Speaker 03:
This case is not about reweighing evidence at the PTAP.

[00:00:41] Speaker 03:
Focusing on the most straightforward issues, it's about a complete absence of evidence on two dispositive points.

[00:00:50] Speaker 03:
The first is getting claim one's order of steps right.

[00:00:54] Speaker 03:
And the second is the absence of evidence about satisfying claim six's requirement

[00:01:01] Speaker 03:
comparing a network destination address in the header.

[00:01:06] Speaker 03:
And to streamline things, everything I'm going to say today assumes that traffic can enter the ring at any node in the ring network.

[00:01:15] Speaker 03:
I'll start with the first absence of evidence regarding the order of steps.

[00:01:19] Speaker 03:
And this argument applies to both Dantoo alone and Dantoo in combination with Aziz.

[00:01:26] Speaker 03:
There is no dispute

[00:01:28] Speaker 03:
that the claim requires identifying to proceed encapsulation.

[00:01:33] Speaker 03:
There is no dispute about what the PTAB and Unified pointed to to establish the claimed encapsulation and when it occurs.

[00:01:43] Speaker 03:
Both point to when traffic arrives at the first node from outside the ring.

[00:01:49] Speaker 03:
So it has to happen first.

[00:01:51] Speaker 03:
Encapsulation has to happen first when it reaches the first node.

[00:01:53] Speaker 03:
There's no dispute about that.

[00:01:56] Speaker 03:
And there's also no dispute.

[00:01:57] Speaker 03:
about what unified in the PTAB 0.2 to establish the identifying step.

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You can see it at appendix 24, which is the PTAB's final decision.

[00:02:10] Speaker 03:
It is determining a corresponding memory portion holding a corresponding forwarding table for a specified VPN according to the identity of the path from which a data packet was received.

[00:02:22] Speaker 03:
And here's the problem.

[00:02:24] Speaker 03:
The path from which the data packet was received has to refer to a path within the ring.

[00:02:32] Speaker 03:
So in other words, this identification step can only happen at the second and subsequent nodes because the determination about which forwarding table to use depends on receiving the traffic from within the ring.

[00:02:48] Speaker 03:
Every single instance in DANTU using the word path refers to it as a path within the ring.

[00:02:54] Speaker 03:
And if you specifically look at the instances in DANTU talking about this selection of a forwarding table, which occurs in the context of figures 9, 10, and 11, every one of them makes clear that the path is solely within the ring.

[00:03:12] Speaker 03:
Let me start with appendix 946, figure 9.

[00:03:16] Speaker 03:
As you may recall from... Yes?

[00:03:18] Speaker 02:
One of the concerns I have is that this question is reviewed by us for substantial evidence.

[00:03:23] Speaker 02:
This is just whether a reasonable fact finder could find as the board did.

[00:03:28] Speaker 02:
And I think there was evidence, at least expert testimony, explanation by an expert to support the board's findings on this issue.

[00:03:39] Speaker 02:
So how do you address that?

[00:03:40] Speaker 02:
Because, you know, again, substantial evidence standard is quite deferential.

[00:03:45] Speaker 03:
Absolutely, Your Honor.

[00:03:46] Speaker 03:
But there still has to be evidence.

[00:03:47] Speaker 03:
And so if we look at what the evidence is that they had two opportunities in their briefing to point to anything specifically in DonTU that showed that a path refers to something other than a path within the ring.

[00:04:03] Speaker 03:
And they don't say anything in their brief about anything from DonTU.

[00:04:06] Speaker 03:
All they point to are some general statements by their expert.

[00:04:11] Speaker 03:
But their expert, if you look at the citations, and we did this in our brief,

[00:04:15] Speaker 03:
And I'll reply based in particular.

[00:04:17] Speaker 03:
Every citation that their expert has, he refers to either figures 9, 10, or 11.

[00:04:25] Speaker 03:
And Dantu is clear that in every one of those cases, what is going on is the path is within the ring network.

[00:04:31] Speaker 03:
They have to present some evidence, other than an expert generally saying, well, yeah, this is coming in from outside the ring.

[00:04:38] Speaker 03:
The expert has to point to something that supports it.

[00:04:42] Speaker 03:
Otherwise, it's Ipsy Dixit, which is not affirmative evidence.

[00:04:46] Speaker 03:
And here, if you look at the things that they're expert pointed to, again, figure 9, the figure itself distinguishes between paths within the ring designated as PTH and the lines to IP nodes.

[00:05:00] Speaker 03:
It distinguishes those two.

[00:05:01] Speaker 03:
And in the text of the specification describing figure 9, it says, again, appendix 955, column 1546 to 47,

[00:05:10] Speaker 03:
Each of the switches include an input to receive data packets for specified paths on the fiber optic ring network.

[00:05:18] Speaker 03:
You can also look at 1532 to 34, which says something very similar.

[00:05:22] Speaker 03:
This is making clear that in the context of figure 9, paths come from within the ring.

[00:05:27] Speaker 03:
We can then turn to figure 10, which is also a flow chart talking about the selection of forwarding tables based on the input path.

[00:05:37] Speaker 03:
And if you look at figure 10, which is appendix 947, it points to step 1006 about receiving user traffic.

[00:05:48] Speaker 03:
Now, how do we know that that user traffic is traffic from within the ring?

[00:05:52] Speaker 03:
Well, it doesn't say receiving IP traffic.

[00:05:55] Speaker 03:
It says receiving user traffic.

[00:05:57] Speaker 03:
Now, why do we know that that distinction is important?

[00:06:00] Speaker 03:
Because if you look at figure 6, which is explicitly the flowchart for what a node does

[00:06:06] Speaker 03:
when it receives traffic from outside the ring.

[00:06:09] Speaker 03:
Figure 6, step 610, talks about receiving IP user traffic.

[00:06:15] Speaker 03:
So if you compare appendix 943, figure 6, with appendix 947, figure 10, you can see that figure 10 is talking about paths within the ring, getting traffic solely within the ring.

[00:06:30] Speaker 03:
And then finally, if you look at figure 11, which is the last instance,

[00:06:34] Speaker 03:
it shows an MPLS packet.

[00:06:36] Speaker 03:
This is appendix 946.

[00:06:38] Speaker 03:
And in the label at the front, it refers to something called the path router, which the p-tab at appendix 71 concluded is the input path ID.

[00:06:50] Speaker 03:
And here's how we know that identification has to happen after encapsulation, because this label, this entire MPLS packet header,

[00:07:00] Speaker 03:
that they contend is encapsulation is already there.

[00:07:04] Speaker 03:
And only in the label can you see where the path route is.

[00:07:07] Speaker 03:
So it has to happen after the process of encapsulation.

[00:07:13] Speaker 03:
All the evidence, again, in DANTU, establishes that path routes refer solely to traffic within the ring.

[00:07:21] Speaker 03:
And they've presented no evidence

[00:07:24] Speaker 03:
to the contrary.

[00:07:25] Speaker 03:
So there's a complete absence of evidence on this point supporting the PTAP.

[00:07:28] Speaker 00:
When you say no evidence, we have to treat the expert's testimony as ifsy-dixy, because the expert did contradict everything you just said.

[00:07:36] Speaker 03:
Isn't that right?

[00:07:38] Speaker 03:
Yes, but if you look at every single thing that the expert said, the expert cites to the same evidence I just did.

[00:07:44] Speaker 03:
Figures 9, 10, 11, and none of that, nothing in DANTU supports contrary interpretation.

[00:07:49] Speaker 00:
How is what you're arguing not asking us to reweigh the evidence?

[00:07:53] Speaker 03:
Because what the experts said is Ipsy Dixit, so it's not evidence.

[00:07:56] Speaker 03:
And so then the other side has to point to some evidence from DANTU that supports their case, and they haven't done it in the brief.

[00:08:02] Speaker 03:
And I challenge you to ask them to do it here, because they won't be able to.

[00:08:04] Speaker 00:
But your argument does require us to say that the expert's testimony amounts to nothing more than Ipsy Dixit.

[00:08:09] Speaker 00:
Absolutely.

[00:08:10] Speaker 00:
If we disagree on that, then you lose.

[00:08:12] Speaker 03:
Yes.

[00:08:14] Speaker 03:
I'll now turn, because I'm running low on time, to Claim 6.

[00:08:19] Speaker 03:
Now Claim 6 is a somewhat related point.

[00:08:21] Speaker 03:
Claim 6 is a refinement of this identification step.

[00:08:25] Speaker 03:
Again, in Claim 1, you're trying to identify which routing table to use for a particular VPN.

[00:08:39] Speaker 03:
based on the input path.

[00:08:41] Speaker 03:
Again, that's based on the input path.

[00:08:43] Speaker 03:
For claim six, it requires that that process, that identification step, be done by comparing a destination address in the header.

[00:08:56] Speaker 03:
But we know

[00:08:57] Speaker 03:
We know that what the PTAB and UNIFID pointed to for this identifying step is looking at the input path to determine which forwarding table to use.

[00:09:08] Speaker 03:
An input path can't be a destination address, and there's no evidence to suggest that it does.

[00:09:16] Speaker 03:
Now, what did the PTAB rely upon?

[00:09:20] Speaker 03:
Well, the PTAB relied upon- Can I just interrupt?

[00:09:22] Speaker 02:
Sure.

[00:09:22] Speaker 02:
I just want to make sure I understand.

[00:09:24] Speaker 02:
looking at the input path, they specifically identified in the header the path information.

[00:09:31] Speaker 02:
Correct, Your Honor.

[00:09:34] Speaker 02:
Do I understand correctly?

[00:09:35] Speaker 02:
I understand them to be saying that when you look at the path, you're going to see the destination.

[00:09:43] Speaker 03:
No.

[00:09:43] Speaker 03:
No, I don't believe that's what they're saying.

[00:09:45] Speaker 03:
And you can't.

[00:09:46] Speaker 03:
It is the input path.

[00:09:47] Speaker 03:
It is the path that the traffic is traveling into the node using.

[00:09:54] Speaker 03:
And let me just give you an example.

[00:09:55] Speaker 03:
If you look at figure 11 in DANTU, it shows an MPLS label.

[00:10:00] Speaker 03:
And it shows the appendix.

[00:10:11] Speaker 03:
So figure 11 is appendix 946.

[00:10:13] Speaker 03:
If you look on the far left, 116 is designated as the path route.

[00:10:18] Speaker 03:
That is what the panel, the PTAB, said is the input path.

[00:10:22] Speaker 03:
And then you look to the right, it's two headings over.

[00:10:24] Speaker 03:
Only then do you come to the destination address.

[00:10:28] Speaker 03:
There are two totally different things.

[00:10:30] Speaker 02:
Now, you're saying the language path route is identified as part of the label in 1116.

[00:10:38] Speaker 03:
Yes.

[00:10:39] Speaker 03:
Path route is part of the label.

[00:10:40] Speaker 03:
And the PTAB said that that is the path ID.

[00:10:42] Speaker 03:
upon which the determination is made about which forwarding table to use.

[00:10:47] Speaker 03:
And let me also say this, determining which forwarding table to use does not determine the destination.

[00:10:51] Speaker 03:
It just determines which forwarding table to use.

[00:10:54] Speaker 03:
You then have to use the forwarding table to make a determination about where it's going.

[00:10:59] Speaker 03:
And by the way, that's not to the ultimate destination.

[00:11:02] Speaker 03:
The forwarding table just says, hey, either send it to the next node or send it out of the network.

[00:11:10] Speaker 03:
This diagram shows you that the input path, aside from just plain language, that input path cannot mean a destination address.

[00:11:19] Speaker 03:
This shows you graphically that those two things are different.

[00:11:24] Speaker 03:
And what the PTAB and UNIFI pointed to to try and support it are figure two and figure seven.

[00:11:31] Speaker 03:
And we showed in our reply brief the reasons why neither of those can inform this process of determining

[00:11:40] Speaker 03:
which forwarding table to use based on the input path.

[00:11:45] Speaker 03:
Both figures 2 and 7, it's determining which forwarding table to use for a VPN.

[00:11:51] Speaker 03:
Neither of those, neither figure 2 nor figure 7, supports VPNs.

[00:11:57] Speaker 03:
And neither provides for multiple forwarding tables.

[00:12:00] Speaker 02:
Mr. Gerst, I just want to note for you that you are in your rebuttal time.

[00:12:04] Speaker 02:
Yes.

[00:12:04] Speaker 02:
So you might want to preserve it.

[00:12:06] Speaker 03:
I'm going to now, unless you have further questions on this point.

[00:12:08] Speaker 03:
Thank you.

[00:12:10] Speaker 03:
Ms.

[00:12:10] Speaker 03:
Oliver?

[00:12:12] Speaker 01:
And may it please the court.

[00:12:13] Speaker 01:
Angela Oliver on behalf of Unified Patents.

[00:12:16] Speaker 01:
We believe this is an issue of simply reweighing the evidence that the board used to support its decision.

[00:12:22] Speaker 01:
For every aspect of the decision, there is expert testimony supported by additional evidence that supports the conclusions and findings that the board ultimately reached.

[00:12:29] Speaker 02:
Could you, for us, please explain what that evidence is on both the point of claim limitation 6.5 and also with respect to the order of operations?

[00:12:44] Speaker 01:
Sure.

[00:12:44] Speaker 01:
And I'll start with the order of operations more broadly.

[00:12:47] Speaker 01:
So my friend on the other side has kind of lumped this into this would affect both the combination of Don2 and Aziz and Don2 alone as to limitation 1.3 in the same way.

[00:12:58] Speaker 01:
Respectfully, it would not.

[00:13:01] Speaker 01:
My friend is relying on figure 11, the MPLS header, to show that this path route has to be in an MPLS header before you can even identify which boarding table should be used.

[00:13:13] Speaker 01:
But respectfully, with respect to the combination of Dante and Aziz, MPLS is not used at all in the combination.

[00:13:19] Speaker 01:
So we can see this when the board explained how this works at appendix page 42.

[00:13:24] Speaker 01:
in 45 through 46.

[00:13:25] Speaker 01:
This is where the board's relying, discussing the combination of DANTU and Aziz.

[00:13:30] Speaker 01:
And so this is just a straightforward combination as to that limitation.

[00:13:34] Speaker 01:
So DANTU discloses receiving the packets, identifying which packets belong to a VPN, and then after that,

[00:13:43] Speaker 01:
adding the encapsulation and encryption method from Aziz to show that encapsulation step.

[00:13:50] Speaker 01:
That is the correct order of events.

[00:13:52] Speaker 01:
There's nothing that has to do there with MPLS headers.

[00:13:55] Speaker 01:
None of the evidence talks about figure 11.

[00:13:57] Speaker 01:
And so that is just a straightforward.

[00:14:00] Speaker 02:
Can you identify?

[00:14:01] Speaker 02:
I'm looking at page 842.

[00:14:03] Speaker 02:
Is there specific portions that you're relying on?

[00:14:06] Speaker 01:
Sure.

[00:14:07] Speaker 01:
So I think the most helpful portion in here is to turn to the expert testimony.

[00:14:11] Speaker 01:
So in the middle of this page, the board cites Dr. Haas's opening declaration, paragraph 77 through 90, which is the initial discussion of this.

[00:14:21] Speaker 01:
And I think particularly paragraph 88

[00:14:23] Speaker 01:
is the most helpful with respect to this order.

[00:14:25] Speaker 01:
That's on appendix page 884.

[00:14:33] Speaker 01:
And so in paragraph 88 of Dr. Haas' opening declaration, kind of in the middle of this paragraph, he sums it all up.

[00:14:40] Speaker 01:
Now he starts the paragraph and he says, what we already know, Donchus knows, receive the data packet, and then... You're somewhere in the middle, like around where it says, given these similarities, or where are you?

[00:14:50] Speaker 01:
Yes, so I think... How many terms following?

[00:14:51] Speaker 01:
Yes, of course.

[00:14:52] Speaker 01:
I think the sentence with given these similarities ties it all up, but actually if we jump a few sentences before that, starting with

[00:14:59] Speaker 01:
For instance, don't use nodes.

[00:15:01] Speaker 01:
I think this is where you can really see the whole order layout.

[00:15:04] Speaker 01:
So don't use nodes, receive the data packet, and then determine whether the packet is associated with a specified VPN.

[00:15:12] Speaker 01:
And then next after that is where the combination with Aziz comes in.

[00:15:17] Speaker 01:
And so Aziz teaches the encapsulation method, which is not disputed that it does teach that.

[00:15:23] Speaker 01:
And then the sentence starting with given these similarities in operations.

[00:15:27] Speaker 01:
a procedure would have been motivated to combine the references by modifying the system of DANTU

[00:15:32] Speaker 01:
to have each VPN-specific routing table perform the function of specifying which packets would be encapsulated and encrypted according to Aziz.

[00:15:40] Speaker 01:
So essentially, it's very straightforward.

[00:15:42] Speaker 01:
Dantu receives the packets.

[00:15:43] Speaker 01:
Dantu identifies which ones are in a VPN.

[00:15:46] Speaker 01:
And then Aziz comes in and says, just like in Aziz, how you would identify which ones need to be encrypted, then you encapsulate those.

[00:15:53] Speaker 01:
In Dantu, you identify which ones belong to a VPN, and then you encapsulate those.

[00:15:58] Speaker 01:
So the order is very clear, and it has nothing to do

[00:16:00] Speaker 01:
with the MPLS header in Figure 11.

[00:16:03] Speaker 01:
So that's just to address the combination of Dantu and Aziz.

[00:16:07] Speaker 01:
We believe the substantial evidence supports that the claim order is taught there by the expert system.

[00:16:12] Speaker 02:
So your view is that the way the expert discussed how they would be combined in and of itself provides the order.

[00:16:20] Speaker 01:
Yes, it does, because he provides exactly which order it should go in, the receiving, then identifying, then encapsulating.

[00:16:26] Speaker 01:
So a similar problem exists with respect to the separate argument about DANTU alone.

[00:16:32] Speaker 01:
Although I don't believe the court needs to reach that argument.

[00:16:35] Speaker 01:
If the court affirms with respect to the combination of DANTU and Aziz teaching the encapsulating limitation, that's enough to address claim one without separately addressing whether DANTU teaches it alone.

[00:16:45] Speaker 01:
We believe that also is supported by substantial evidence, specifically because of the MPLS push operations that occur there.

[00:16:52] Speaker 01:
And my only point here is simply to say that while MPLS is relevant to that argument, nowhere in the analysis of limitation 1.2, when the board is discussing the identifying limitation, does the board rely on that figure 11 MPLS header.

[00:17:08] Speaker 01:
Instead, the board cites Dr. Haas's testimony at paragraph 70, which is much broader when it's talking about path information that is used to identify which packets belong to a VPN.

[00:17:21] Speaker 01:
And that actually transitions nicely into a discussion of Claim 6.

[00:17:27] Speaker 01:
So Claim 6 provides further details regarding the identifying limitation.

[00:17:33] Speaker 01:
And there, again, there is nothing that relies affirmatively on Figure 11's MPLS header that came up in this section in response to an argument

[00:17:45] Speaker 01:
by the patent owner that header information would not contain path information.

[00:17:49] Speaker 01:
Well, one example of that certainly is figure 11.

[00:17:52] Speaker 01:
It does contain path information in a header.

[00:17:54] Speaker 01:
But that's not specifically what was relied on with respect to claim six.

[00:17:57] Speaker 01:
As we pointed out in our brief, the board relied on the destination node ID to teach that.

[00:18:04] Speaker 01:
And specifically, you can see this on appendix page 72 of the board's analysis.

[00:18:12] Speaker 01:
So at the top of this page,

[00:18:15] Speaker 01:
The board says, the first full complete sentence, the board says, as petitioner argues, we determine that Don through teaches identifying the received packets as associated with the VPN by examining header information for source and destination address information.

[00:18:33] Speaker 01:
It's not looking for that path ID or path route, excuse me,

[00:18:36] Speaker 01:
that's mentioned in the MPLS header specifically.

[00:18:39] Speaker 01:
This is broader.

[00:18:40] Speaker 01:
This is when an IP packet, which always carries a source and destination address, comes and arrives at the ring.

[00:18:47] Speaker 01:
It has address information that shows what route it is taking.

[00:18:51] Speaker 01:
And Dr. Haas discussed this, again, in paragraph 57, which is cited by the board here and elsewhere as well.

[00:19:03] Speaker 01:
And one final paragraph just to support this.

[00:19:05] Speaker 01:
I believe paragraph 61 of the expert declaration also supports this.

[00:19:10] Speaker 01:
Finally, the last point I will make, unless the court has other questions, is that in the gray brief, my friend on the other side raises some additional arguments regarding whether the board should have relied on Figure 2 and Figure 7 with respect to its analysis.

[00:19:23] Speaker 01:
of claim six, including the destination note ID in figure seven.

[00:19:28] Speaker 01:
Those arguments were not fleshed out in the blue brief.

[00:19:31] Speaker 01:
And so respectfully, we believe the court should not separately address those.

[00:19:34] Speaker 01:
But in any event, they are supported by substantial evidence.

[00:19:37] Speaker 01:
Figure two is just a general architecture that a procedure would have understood to apply to the embodiments discussed here as well.

[00:19:46] Speaker 01:
Unless the court has additional questions?

[00:19:49] Speaker 01:
No, thank you.

[00:19:50] Speaker 01:
Thank you.

[00:19:54] Speaker 02:
Mr. Verst?

[00:20:09] Speaker 03:
Thank you.

[00:20:09] Speaker 03:
Let me start with the order of steps.

[00:20:12] Speaker 03:
So council got up to provide you with evidence that the order of steps goes in the order that they contend and the PTAB contends it did.

[00:20:19] Speaker 03:
And look at what they say.

[00:20:20] Speaker 03:
They say that Appendix 884

[00:20:23] Speaker 03:
broad conclusory statements by their expert without any citation whatsoever.

[00:20:30] Speaker 03:
It cannot be enough to win at the PTAB to just present an expert who cites no evidence and presents nothing.

[00:20:37] Speaker 03:
Their expert says that the traffic, what they quoted was, for instance, Don Tsu's notes receive the data packet and then determine whether the packet associated with a specified VPN.

[00:20:47] Speaker 03:
And if so, the packet is routed according to a specified specific table.

[00:20:50] Speaker 03:
That is not what Don Tsu says.

[00:20:53] Speaker 03:
And if you look at figures in 9, 10, and 11, it is consistent.

[00:20:57] Speaker 03:
There is not a single instance that they can point to.

[00:21:01] Speaker 03:
All they can point to is this unsupported statement by their expert.

[00:21:04] Speaker 03:
That is classic Ipsy Dixit.

[00:21:06] Speaker 03:
It cannot support the finding here.

[00:21:08] Speaker 03:
Otherwise, any time you wanted to win at the BTEC, you could present an expert who would say anything without any support, and that would provide substantial evidence.

[00:21:15] Speaker 02:
And it's your position that a person of ordinary skill and the art would not make the combination in this way?

[00:21:22] Speaker 03:
The issue is the order, yes.

[00:21:25] Speaker 02:
I understand them to be saying that the way the two references are combined is what creates the order that satisfies the claim.

[00:21:38] Speaker 02:
And your argument is that there's no basis in support for that.

[00:21:41] Speaker 02:
Do I have that correct?

[00:21:44] Speaker 03:
More than that, Your Honor.

[00:21:45] Speaker 03:
To the extent they're making that argument,

[00:21:46] Speaker 03:
It is reordering Donsu.

[00:21:48] Speaker 03:
So you're modifying Donsu in a way that they never presented.

[00:21:52] Speaker 03:
If this is an obvious in this case, they are then reordering Donsu.

[00:21:55] Speaker 03:
And they've never provided a motivation to do that in Donsu, to change the order.

[00:22:02] Speaker 03:
There is no evidence anywhere in the record of that.

[00:22:06] Speaker 03:
Just quickly turning to claim six, Your Honor.

[00:22:08] Speaker 03:
It is not limited to figure 11.

[00:22:11] Speaker 03:
Figure 11 is illustrative.

[00:22:13] Speaker 03:
Figures 9, 10, and 11 are all consistent that what is looked at is the input path.

[00:22:22] Speaker 03:
Yes, in figure 11 there is a destination address, but it is explicitly not considered during this critical step of selecting a forwarding table that the PTAB and UNIFI pointed to

[00:22:36] Speaker 03:
to establish the identifying step.

[00:22:38] Speaker 03:
Again, go back to the PTAP decision.

[00:22:40] Speaker 03:
It says, what we're looking for for step 1.2 is selecting the forwarding table based on the input path.

[00:22:49] Speaker 03:
So what appears elsewhere is irrelevant.

[00:22:53] Speaker 03:
That's not what is considered.

[00:22:55] Speaker 03:
And frankly, and then also with respect to claims to figures 2 and 7, which counsel referred to, they cannot support

[00:23:02] Speaker 03:
They cannot support, for the reason I stated before, the conclusion reached by the PTAB and UNIFID about using a destination address.

[00:23:12] Speaker 03:
Nothing about selecting a forwarding table based on input path ID relates to a destination address.

[00:23:21] Speaker 03:
So there's just simply no evidence other than broad unsupported statements by an expert.

[00:23:24] Speaker 03:
And that cannot be enough to win at the PTAB or here, Your Honor.

[00:23:29] Speaker 03:
Thank you.

[00:23:32] Speaker 02:
The case will be submitted.

[00:23:34] Speaker 02:
Thank you, counsel, for your time.