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

[00:00:01] Speaker 02:
Now we finally come to case number 22, 1026 in the Zahner Design Group Limited.

[00:00:08] Speaker 02:
Mr. Collin.

[00:00:10] Speaker 03:
May it please the court.

[00:00:11] Speaker 03:
My name is Morris Cohen and I represent the Zahner Design Group in this matter.

[00:00:15] Speaker 03:
Your Honors, when Mr. Zahner's specification said that the internal and external edges of his ring need not be rounded, he then showed an example of eight... But preferably or so, right?

[00:00:30] Speaker 03:
Yes, Your Honor.

[00:00:30] Speaker 03:
He then showed an example of eight right-angled edges, and figure 4C as an example of what he meant, showed that right-angled edges were within his contemplation for the internal edges.

[00:00:44] Speaker 01:
So those are the external edges, right?

[00:00:46] Speaker 03:
Yes, but he said that is correct, Your Honor.

[00:00:48] Speaker 03:
He said his internal and or external edges need not be rounded.

[00:00:53] Speaker 03:
And then he showed that as an example of the external edges.

[00:00:55] Speaker 03:
But his statement was also that the internal edges were the same.

[00:01:00] Speaker 03:
And in fact, Your Honor, when we look at all of the evidence, all of the evidence consistently supports this same position, this same conclusion.

[00:01:10] Speaker 03:
If we look for example at his manufacturing specifications, his manufacturing specifications with respect to the RF embodiment indicate that the surface of the ring must be of a uniform height.

[00:01:24] Speaker 03:
for that particular manufacturing embodiment.

[00:01:28] Speaker 03:
A rounded edge is not a uniform height.

[00:01:29] Speaker 03:
It tapers downward.

[00:01:31] Speaker 01:
The only way it could be a uniform height... That's the edging though.

[00:01:34] Speaker 01:
That's not the actual surface of the ring itself.

[00:01:37] Speaker 03:
It's the surface of the... I'm sure I don't understand the question.

[00:01:41] Speaker 01:
Well, what we're looking at essentially are flat panel rings, right?

[00:01:46] Speaker 01:
Yeah.

[00:01:46] Speaker 01:
And if you put the shower curtain over a row of these flat panel rings, you're going to have an even surface, regardless of whether the internal edging is at a right angle or maybe it's beveled or something else.

[00:02:03] Speaker 03:
Oh, I see.

[00:02:04] Speaker 03:
So in his manufacturing specification, he indicates that when you're lining up all of the materials, that the surface must be of the same height.

[00:02:12] Speaker 03:
And the ring would not have the same height if the edge is rounded, because that edge would go downward.

[00:02:18] Speaker 03:
It would not be the same height.

[00:02:20] Speaker 04:
It would have the same height if the edge was sharper than 90 degrees, correct?

[00:02:28] Speaker 03:
Well, if it were 90 degrees or under, but under wouldn't be

[00:02:33] Speaker 03:
it wouldn't be manufacturable or hygienic.

[00:02:35] Speaker 03:
You wouldn't use an internal edge, it's a cut-in, and also that would collect bacteria.

[00:02:41] Speaker 03:
You would have either a right angle or a rounded edge.

[00:02:45] Speaker 01:
What about if it doesn't cut down at 90 degrees, but it's more like 150 degrees?

[00:02:52] Speaker 03:
150 degrees outward.

[00:02:54] Speaker 03:
Like a beveled edge.

[00:02:55] Speaker 03:
See, like this.

[00:02:56] Speaker 01:
Instead of like this.

[00:02:57] Speaker 03:
Yes, I understand.

[00:02:58] Speaker 03:
Well, in that case, it would not be the same height.

[00:03:01] Speaker 03:
It would go out.

[00:03:02] Speaker 03:
And then again, it wouldn't be consistent with that particular manufacturing embodiment, the RF embodiment.

[00:03:08] Speaker 01:
What I have about this manufacturing specification argument is

[00:03:12] Speaker 01:
wasn't really meaningfully raised to the board below.

[00:03:16] Speaker 01:
You make a quick reference to it in your board brief, and then in a footnote, you cite to a couple figures.

[00:03:23] Speaker 01:
And I'll be honest with you, when I looked at those figures, I couldn't make heads or tails of them just looking at the figures alone.

[00:03:32] Speaker 01:
And then only after reading your blue brief, which then puts in a few pages trying to walk us through all of that, it still was less than clear to me that those manufacturing specifications demand that you have a right angle interior edge.

[00:03:49] Speaker 01:
But by and large, the main problem I have is that this looks like an argument that was just too skeletal and conclusory below to be regarded as a preserved argument.

[00:03:59] Speaker 03:
Well, we raised it in the opening brief of the PTAB at 1241 and note 7.

[00:04:04] Speaker 03:
Then we released it in the reply at 1287 and 1293.

[00:04:07] Speaker 01:
Well, you had a single basic generic statement saying, oh, and then there's these manufacturing specifications.

[00:04:14] Speaker 01:
But the board requires a little bit more than that.

[00:04:20] Speaker 01:
You need to explain yourself in terms of what it is about the content of those manufacturing specifications that forces a conclusion that these utility patent drawings have a particularized appearance, three-dimensional appearance.

[00:04:36] Speaker 01:
And that kind of argumentation wasn't really presented below.

[00:04:40] Speaker 01:
I mean, if you had given the Federal Circuit that same

[00:04:44] Speaker 01:
level of quality of argument in your blue brief, I wouldn't have known what to do with it.

[00:04:52] Speaker 01:
I would have basically said, this isn't a real argument.

[00:04:56] Speaker 01:
So I guess that's the main concern I have.

[00:04:59] Speaker 01:
And then the second concern that I have is, as we've been talking about, I don't see why it requires some 90 degree right angle interior edge.

[00:05:10] Speaker 03:
Well, Your Honor, my point that I was making is that

[00:05:13] Speaker 03:
Mr. Zahner was in possession of right angle edges.

[00:05:16] Speaker 03:
There are different ways to do his rings.

[00:05:18] Speaker 03:
It says need not be rounded, but preferably so, and an example of need not be rounded was right angle edges.

[00:05:25] Speaker 03:
The question is was he in possession of right angle edges, and his figure shows that he was in possession of that.

[00:05:32] Speaker 03:
And in addition, the evidence, for example... Well, maybe not right angle edges in the abstract.

[00:05:37] Speaker 01:
It was whether he was in possession of and clearly conveyed to a skilled artisan of a specific design, three-dimensional design of these shower rigs.

[00:05:47] Speaker 01:
And it's hard

[00:05:48] Speaker 01:
to rely on two-dimensional drawings from a utility patent, which are really more concept-based, less ornamentation, three-dimensional design-based, to make that conclusion.

[00:06:03] Speaker 01:
And this was a fact-finding by the board below, which enjoys substantial deference here on appeal.

[00:06:11] Speaker 03:
Except that the PTO's basis for their fact-finding was a false premise.

[00:06:15] Speaker 03:
The PTO says

[00:06:16] Speaker 03:
that the rings in figure four are all rounded and they have no shading.

[00:06:21] Speaker 03:
Therefore shading is not relevant.

[00:06:23] Speaker 03:
But there's nothing in the record where it says that figure four has got rounded edges.

[00:06:27] Speaker 03:
On the contrary, figure four has right angled edges.

[00:06:30] Speaker 03:
So the premise of the PTA view is incorrect.

[00:06:33] Speaker 03:
In addition,

[00:06:34] Speaker 03:
The concept of question is one of ordinary skill, what a skill designer would understand.

[00:06:39] Speaker 03:
And we showed that a skill designer and the expert, likewise specified, would understand that rounded edges are shown by contract-centric shading.

[00:06:48] Speaker 03:
A lack of shading, as was shown in the particular drawing that was in the priority document, indicates a right-angled edge.

[00:06:56] Speaker 04:
Mr. Carr, let me interrupt you, because the lack of shading simply shows that

[00:07:03] Speaker 04:
that there's an edge.

[00:07:04] Speaker 04:
But if it was more than 90 degrees, that drawing would look the same, would it not?

[00:07:10] Speaker 04:
Figure 21?

[00:07:11] Speaker 03:
Well, that would not be the type of ring that one would use because it would collect bacteria.

[00:07:17] Speaker 03:
But another question.

[00:07:18] Speaker 04:
But I mean, you'd agree with me that if the edge was more than 90 degrees, figure 21 would be correct.

[00:07:28] Speaker 03:
Well, figure 21 could refer to an angle more than 90 degrees.

[00:07:33] Speaker 04:
Figure 21, therefore, does not necessarily disclose a right angled edge.

[00:07:42] Speaker 03:
Well, that's why we look at the specification, Your Honor.

[00:07:44] Speaker 03:
And the specification says the edge need not be rounded.

[00:07:48] Speaker 03:
and then it shows an example, a right angle.

[00:07:51] Speaker 03:
A right angle was certainly within Mr. Zanner's contemplation because he shows a right angle.

[00:07:57] Speaker 03:
If he did not show any examples of right angles, if there was no indication that he was in possession of a right angle, that would be one thing.

[00:08:03] Speaker 03:
But he specifically says the internal edge need not be rounded, and he shows a right angle of what he means.

[00:08:09] Speaker 03:
Thus, the internal edge

[00:08:11] Speaker 03:
of this particular figure can be a right angle.

[00:08:14] Speaker 03:
It could also be more than a right angle, but the question is whether he possessed the right angle.

[00:08:18] Speaker 04:
It's not a question of what it could be.

[00:08:21] Speaker 04:
The question is what is disclosed.

[00:08:24] Speaker 01:
Right, so Mr. Zahner disclosed... It's in your position that in that utility patent drawing, it's necessarily disclosing only a right angle interior edge for those shower rings?

[00:08:36] Speaker 03:
So, you're referring to figure 21 or a particular figure?

[00:08:40] Speaker 03:
So, figure 21 shows a right angle edge because there's no shading.

[00:08:45] Speaker 01:
Only a right angle edge?

[00:08:47] Speaker 01:
It's only showing one singular embodiment, the right angle edge embodiment?

[00:08:52] Speaker 01:
Well, as Judge Lin... It's just a yes or no question.

[00:08:55] Speaker 01:
Is it yes or is it no?

[00:08:57] Speaker 03:
No, I don't believe it only conveys the right angle.

[00:08:59] Speaker 01:
Okay, what else could it be encompassing?

[00:09:01] Speaker 03:
I believe it conveys the right angle, and then in conjunction with the disclosure, the disclosure says alternatively it can be rounded.

[00:09:09] Speaker 03:
So I think if you read the two together.

[00:09:12] Speaker 01:
So then you're saying figure 21 is really agnostic to in terms of what it's illustrating as to be the interior edge of the shower ring.

[00:09:23] Speaker 03:
I think that figure 21 shows the right angle, but the disclosure indicates that it can also alternatively be rounded.

[00:09:29] Speaker 01:
So I guess that's the point, is that the figure in light of the statements and the specification that the edging can be all sorts of different things, preferably rounded but not necessarily so, suggests that the figures themselves likewise aren't really showing any particular

[00:09:47] Speaker 01:
specific embodiment of what the interior edging is going to be, it's just more of a generic picture that's agnostic to the particular edging as displayed in that particular figure.

[00:09:59] Speaker 03:
No, I wouldn't say that because, for example, we have the disclosure that the internal edge can be a right angle.

[00:10:05] Speaker 03:
That's specifically disclosed and shown.

[00:10:08] Speaker 03:
In addition, rule 84M indicates that shading is required for rounding, but it's not required for a flat surface.

[00:10:17] Speaker 01:
and this has got no shading on it, so that indicates that we're... There's something in the rules or the MPEP that mandates a reading of a figure without shading as necessarily understanding that a three-dimensional version of that figure has right angle edges?

[00:10:36] Speaker 01:
Rule 84M says that... It doesn't say that that's necessarily so, correct?

[00:10:42] Speaker 03:
Well, rule 84M says that if it's rounded, it needs to have shading.

[00:10:46] Speaker 01:
But if there's no shading, what you're asking for potentially impacts all utility patent drawings that are two-dimensional renditions of some particular embodiment.

[00:11:04] Speaker 01:
Almost none of those have any shading when it comes to utility patent drawings.

[00:11:09] Speaker 01:
And are you saying that when we look at utility patent drawings, all nine million patents, they all are illustrating a three-dimensional embodiment with right-angled edges, both interior and exterior, because they don't have any shading?

[00:11:26] Speaker 03:
Well, I can't speak to a case not before us, but I can say that the rule, rule 84, says the flat areas may also be lightly shaded.

[00:11:35] Speaker 03:
It's completely optional if it's flat.

[00:11:37] Speaker 03:
So the fact that there's no shading indicates it's flat.

[00:11:40] Speaker 01:
And here we have expressed... OK, wait, wait, wait.

[00:11:43] Speaker 01:
You spoke a little too quickly.

[00:11:45] Speaker 01:
Sorry.

[00:11:46] Speaker 01:
Rule 0.184M says what?

[00:11:48] Speaker 03:
That flat parts may also be lightly shaded.

[00:11:52] Speaker 03:
It's optional for a flat part.

[00:11:54] Speaker 01:
OK, so to get back to my question, there is no requirement 84M that forces us to read two dimensional figures without shading as having right angle edges.

[00:12:10] Speaker 03:
Well, I believe that rule 84M requires shading if there's a rounding.

[00:12:17] Speaker 01:
It says, quote, If you absolutely want to convey rounded edges, then yes, you have to have shading.

[00:12:25] Speaker 01:
But is the converse necessarily so?

[00:12:29] Speaker 01:
That any lack of shading necessarily means that it's a right angle edge?

[00:12:33] Speaker 01:
Is that what Rule 84 says?

[00:12:35] Speaker 01:
I don't read it that way, but if you have some particular words in 84M you want to point me to, I'd like to see it.

[00:12:42] Speaker 03:
Yes.

[00:12:42] Speaker 03:
In Rule 84, it says flat parts may, and I'm emphasizing the may, also be lightly shading.

[00:12:48] Speaker 03:
And it also says that shading is used to indicate spherical, cylindrical, and conical elements.

[00:12:55] Speaker 03:
the element is not shaded shows that it's flat.

[00:12:58] Speaker 03:
Otherwise, it would have had to be shaded.

[00:13:00] Speaker 01:
That's not what the rule says, though.

[00:13:01] Speaker 03:
Well, that's how I will read the rule requiring that if it's rounded, spherical, and so forth, there must be shading.

[00:13:07] Speaker 03:
And that if it's flat, it's optional.

[00:13:09] Speaker 03:
So when the shading is left off, that indicates that it's flat.

[00:13:12] Speaker 03:
And likewise, the disclosure that we said before.

[00:13:15] Speaker 01:
Okay, so then that goes back to my question.

[00:13:17] Speaker 01:
Figure 21, there's no shading, so therefore it must be an only illustrating a right angle edge.

[00:13:24] Speaker 03:
As depicted in that figure, it's a right angle edge.

[00:13:28] Speaker 03:
The description also says that alternative embodiments you can round it.

[00:13:32] Speaker 03:
But the figure itself shows a right angle edge, as also explained before.

[00:13:38] Speaker 03:
Internal edges need not be rounded, and it shows the right angle edge.

[00:13:42] Speaker 01:
Did your utility patent expire yet?

[00:13:44] Speaker 03:
the utility patent on didn't this yes yes yes yes yes and now you're getting got a design patent on one embodiment covered by utility years ago we got a designed by national that design patent doesn't expire for maybe another decade or something like that uh... i don't think i think it's uh... several years about uh... i could look at the date if i look at the uh... yesterday i think it's it's wondering why isn't this uh...

[00:14:11] Speaker 01:
a candidate for obviousness type double patenting or just a straight double patenting rejection because it's an unjustified time-wise extension of a term.

[00:14:20] Speaker 01:
uh... for an embodiment that is clearly covered by the utility claims well that issue wasn't raised and um... that that was that is just not before the court was never raised below and it is a design patent is co-owned by the same person who owns the utility patent that's correct yes it's owned by the same person otherwise the general hallmarks for double-patent rejections

[00:14:44] Speaker 03:
Well, not necessarily.

[00:14:45] Speaker 03:
First of all, if that issue had been raised, the applicant could have addressed it.

[00:14:52] Speaker 03:
It's not before the court because it was never raised.

[00:14:55] Speaker 03:
Also, the whole question of such a

[00:14:59] Speaker 03:
of such an issue goes into its own separate area of law, which was never briefed and never addressed.

[00:15:05] Speaker 03:
I don't know that that's really an issue.

[00:15:08] Speaker 03:
But I would say that the PTO's position is based on a false premise.

[00:15:13] Speaker 03:
They have no site for showing that Figure 4 is rounded, and they rely on the lack of shading in Figure 4, which is based on a false premise.

[00:15:26] Speaker 03:
I reserve the remainder of my time.

[00:15:29] Speaker 02:
Thank you.

[00:15:31] Speaker 02:
Thank you.

[00:15:32] Speaker 00:
Mr. Hickman?

[00:15:32] Speaker 00:
Morning, Your Honors.

[00:15:33] Speaker 00:
May it please the Court?

[00:15:35] Speaker 00:
I agree with the questions that the Court has pointed out so far to Appellants' Council.

[00:15:41] Speaker 00:
And just to bring things back to basics, to win this appeal, Mr. Zahner must show that there is no substantial evidence to support the finding that he had not designed interior right angle edges by the earlier filing date.

[00:15:57] Speaker 00:
But a comparison of two drawings supplies the core of that substantial evidence.

[00:16:03] Speaker 00:
And those two drawings, as the court is aware, are figure 21 from the priority application in figure two in the current design patent.

[00:16:18] Speaker 00:
And they are depicted side by side on pages one and two of our red brief.

[00:16:24] Speaker 00:
The court has

[00:16:26] Speaker 00:
created a body of precedent which gives us guides for how to compare those two figures.

[00:16:33] Speaker 00:
Owens, Daniels, and Bascath, all three of those cases, provide us with guides for how to analyze and compare those drawings.

[00:16:44] Speaker 00:
And what they tell us to do is look for whether there is clear visibility, a clear visual indication of possession of the design in the earlier drawing.

[00:16:55] Speaker 00:
We ask whether new matter has been added, and we can also look at whether perhaps there was an addition of lines in the new drawing that would create new matter.

[00:17:05] Speaker 00:
And in figure two of the current design patent under re-examination, we can see that it is clearly different than the figure in the prior application.

[00:17:18] Speaker 00:
It's in three dimensions, whereas in the prior application it was in two dimensions.

[00:17:24] Speaker 00:
In the prior drawing, we can't even really see inside that ring anything about the nature of whether it's flat or whether there's a right angle or whether there could be beveling or things like that.

[00:17:38] Speaker 00:
So that, I believe, is the core of the substantial evidence.

[00:17:44] Speaker 00:
The court already covered quite a bit in the opening part of the argument on the issues that were raised in the briefing.

[00:17:50] Speaker 00:
answer any further questions if the court has any.

[00:17:53] Speaker 00:
If not, I am willing to see the rest of my time.

[00:17:57] Speaker 02:
Any questions?

[00:18:00] Speaker 02:
Any more questions?

[00:18:01] Speaker 02:
Thank you.

[00:18:08] Speaker 03:
Thank you, Your Honor.

[00:18:10] Speaker 03:
The Patent Office's response doesn't address the question that we raised, which is that the premise of the PTAB decision was that Figure 4 is a preferred embodiment with all rounded edges.

[00:18:22] Speaker 03:
There's no basis for that in the record.

[00:18:24] Speaker 03:
There's nothing in the record that indicates that what the PTAB relied upon is actually what the specification says.

[00:18:32] Speaker 03:
It's a false premise.

[00:18:34] Speaker 03:
The specification refers to Figure 4

[00:18:38] Speaker 03:
and then it shows right angled edges.

[00:18:40] Speaker 03:
To say that figure 4 only covered rounded edges is inconsistent with the figure, but that's what the PTAB relied upon at the appendix at 11.

[00:18:50] Speaker 03:
They said that since this figure is all rounded edges and there's no shading, shading is irrelevant.

[00:18:57] Speaker 03:
But that figure is not all rounded edges.

[00:18:59] Speaker 03:
As we had shown, that figure shows right angled edges.

[00:19:02] Speaker 03:
And the patent itself says the internal and external edges need not be rounded, although they are preferably so.

[00:19:11] Speaker 03:
And then when it shows this example of right angle edges, it indicates that when it says need not be rounded, it includes right angles as an option.

[00:19:20] Speaker 03:
It's not the only option.

[00:19:22] Speaker 03:
There are other options for the particular edges.

[00:19:25] Speaker 03:
But the question before the court is simply whether or not a right angled edge

[00:19:31] Speaker 03:
is one of the options that was in Mr. Zahner's possession.

[00:19:34] Speaker 03:
We submit that a right angled edge certainly was within his possession because he showed a right angled edge, he discussed that need not be rounded includes a right angled edge, and all the evidence is consistent with a right angled edge.

[00:19:48] Speaker 03:
Whether we give more or less evidence to particular aspects, it's all consistent.

[00:19:53] Speaker 03:
There's no evidence whatsoever

[00:19:55] Speaker 03:
that contradicts Mr. Zahner's position that a right-angled edge was in his possession.

[00:20:00] Speaker 03:
Whether we give less or more weight to the manufacturing specification, less or more weight to the shading, they all come to the same consistent conclusion.

[00:20:08] Speaker 03:
And that conclusion is that he contemplated a right-angled edge as one of his options, not the only option again, but one of his options.

[00:20:15] Speaker 03:
And one would have to really disregard the showing of right-angled edges to say that Mr. Zahner had not considered or thought of right-angled edges.

[00:20:23] Speaker 03:
And it's also somewhat illogical that a designer would not know of right-angled edges, considering that he showed it, considering the fact that he doesn't have shading, considering the fact that a uniformed surface in the manufacturing specifications requires a right-angled edge, considering the fact that an expert testified as to what one of ordinary skill would understand from the drawing.

[00:20:45] Speaker 03:
And that is the standard that this court has put forward.

[00:20:48] Speaker 03:
Possession.

[00:20:49] Speaker 03:
What would a skilled designer understand

[00:20:52] Speaker 03:
from Mr. Zahner's specification, from his disclosure and so forth.

[00:20:57] Speaker 03:
And the expert testified as to that, and the PTAB did not give any weight whatsoever to that expert testimony.

[00:21:04] Speaker 03:
And that was contrary to this court's decision in Altair, in which this court specifically said that to disregard expert testimony is an abuse of discretion.

[00:21:15] Speaker 03:
for the PTAB not to give any weight whatsoever to the expert declaration, to give no weight to the manufacturing specifications, even though it was cited, to give no weight to the shading, even though their reason is based on a false preference.

[00:21:28] Speaker 03:
That's all an abuse of discretion, arbitrary and capricious.

[00:21:32] Speaker 03:
The PTAB says that shading is not required because this particular ring is not shaded and it's all rounded.

[00:21:38] Speaker 03:
But one just needs to look at it and see that it's not all rounded.

[00:21:41] Speaker 03:
It's got right angles within it.

[00:21:43] Speaker 03:
So it's hard to justify a position by the PTAB that simply ignores the fact that all the evidence for Mr. Zahner is consistent and which is built upon a false premise.

[00:21:54] Speaker 03:
It's the premise that a particular ring that didn't have shading was rounded when clearly it was not rounded.

[00:22:00] Speaker 03:
And I would add that this position is also consistent with the regulations, which says that flat surfaces need not be shaded.

[00:22:08] Speaker 03:
It's optional.

[00:22:10] Speaker 03:
It's also consistent with what the original examiner found.

[00:22:13] Speaker 03:
The original examiner understood completely that this particular ring was disclosed in the parent.

[00:22:19] Speaker 03:
Even the examiner in this re-examination concluded the same before he, Swiss Fanti, reversed himself without explanation.

[00:22:28] Speaker 03:
He reversed his own position after finding their priority and then didn't explain what the basis was for reversing his position.

[00:22:35] Speaker 03:
In fact, there was no substantial new question of patentability to the extent that

[00:22:40] Speaker 03:
The very same evidence before the PTAB is the evidence that the original examiner already considered.

[00:22:46] Speaker 03:
The original examiner already considered all of this evidence and found priority, and then the PTAB later disregarded that, but there was no new question.

[00:22:54] Speaker 03:
There was nothing new here that was not before the original

[00:22:58] Speaker 03:
examiner who found priority.

[00:23:00] Speaker 03:
And likewise, as we had said, the evidence is all consistent.

[00:23:05] Speaker 03:
The right angle edge was within Mr. Zahner's possession.

[00:23:08] Speaker 03:
Is there any other questions from the court before I... Okay, thank you, Your Honor.

[00:23:14] Speaker 02:
Thank you.

[00:23:15] Speaker 02:
Thanks to both counsels.

[00:23:17] Speaker 02:
The case is taken under submission.

[00:23:19] Speaker 02:
That concludes this panel's arguments for this session.