[00:00:00] Speaker 04:
OK, to proceed with the arguments for this morning, the first sergeant case is number 21, 1605 Newhart Incorporated against Sansun Electronic Company Limited.

[00:00:14] Speaker 04:
Mr. Millican?

[00:00:15] Speaker 04:
Please proceed when you're ready.

[00:00:23] Speaker 01:
Thank you, Judge Newman.

[00:00:27] Speaker 01:
Good morning, Your Honors.

[00:00:28] Speaker 01:
It may please the court.

[00:00:30] Speaker 01:
The board's conclusions on written description and obviousness were erroneous.

[00:00:34] Speaker 01:
The board's written description analysis improperly limited the specifications disclosure to a preferred embodiment in violation of this court's precedence.

[00:00:44] Speaker 01:
And it improperly ignored the predictability of the technology, again, in violation of this court's precedence.

[00:00:50] Speaker 01:
As to obviousness, the board's finding that real contains three terminals is inconsistent with real's

[00:00:57] Speaker 01:
own disclosures, and it rests on an unreasonably broad construction of the term terminal.

[00:01:02] Speaker 01:
I'll begin with written description.

[00:01:05] Speaker 01:
It's undisputed here that there are only two possible orientations for inductor coils.

[00:01:11] Speaker 01:
You can have them side by side, or you can have one inside another one, or concentric.

[00:01:18] Speaker 01:
And it's also undisputed that both orientations operate in a predictable way.

[00:01:23] Speaker 01:
It's undisputed that the specification discloses, quote, adjacent inductor coils.

[00:01:30] Speaker 01:
And it's undisputed that the word.

[00:01:31] Speaker 03:
Council.

[00:01:32] Speaker 01:
Yes.

[00:01:32] Speaker 03:
Do you agree, though, that when it's talking about the adjacent coils, it's in the context of the concentric embodiment depicted in the figures?

[00:01:41] Speaker 01:
I think that in column 19, when it discusses concentric coils, it says such as, and then it gives the figure three example, which is concentric.

[00:01:51] Speaker 01:
But in column 23, lines 37 to 39, it talks about adjacent coils generally and does not tie it specifically to any embodiment that's recited in the figures.

[00:02:05] Speaker 03:
Do you think it's unreasonable for the board to have made the fact-finding of no written description when the specification talks about the importance of having a smaller footprint and it would seem that a concentric design would have a smaller footprint?

[00:02:21] Speaker 01:
I do think that it's unreasonable, Your Honor, particularly because the board did not acknowledge that there were only two possible arrangements and that they both operate predictably.

[00:02:33] Speaker 01:
And I think this court made clear in global IP holdings that predictability is a required aspect of the analysis.

[00:02:40] Speaker 03:
And I think the board's- If it's predictable, if it doesn't satisfy the requirement of the smaller footprint, then would that not be a reasonable finding?

[00:02:50] Speaker 03:
I'm just trying to get your response to that.

[00:02:52] Speaker 03:
Because to me, that was pretty compelling evidence in the spec when it was talking about the desire to have a smaller footprint.

[00:02:59] Speaker 01:
Right, so I think that the smaller footprint is an advantage of the concentric embodiment And I think that's why the specification focuses on the concentric embodiment because it allows it to be smaller But the principal purpose of the invention is to have this three terminal structure where you have the terminals connected to the coils in different configurations such that you can produce a tunable inductance and

[00:03:25] Speaker 01:
And that's possible to do with either the side-by-side or the concentric arrangement.

[00:03:31] Speaker 01:
And so I submit that the primary purpose of the invention is realized regardless of which arrangement that you choose.

[00:03:39] Speaker 01:
And I think it's important to point out that this patent actually uses the word adjacent a lot.

[00:03:45] Speaker 01:
It's not just talking about adjacent coils.

[00:03:48] Speaker 01:
And virtually every time it uses the word adjacent, it uses it to mean side by side.

[00:03:54] Speaker 01:
For example, column 5, line 35, it refers to, quote, adjacent antennas.

[00:03:59] Speaker 01:
It means the antennas are next to each other.

[00:04:02] Speaker 01:
Column 6, line 42, it says vias positioned adjacently.

[00:04:06] Speaker 01:
It means the vias are next to each other.

[00:04:08] Speaker 01:
column 10, line 11, it says adjacent wire strands.

[00:04:11] Speaker 01:
It means the wire strands are next to each other.

[00:04:14] Speaker 03:
And so the point is that... What if I disagree with you that the specification when it talks about adjacent in the context of the coils, it only means concentric?

[00:04:24] Speaker 03:
Then should I really give much weight to your evidence that adjacent in other contexts might mean side by side?

[00:04:33] Speaker 01:
Well, so as an initial matter, Your Honor, I point out again that passage in column 23 that I referred to uses the word adjacent not in the context of the preferred concentric embodiment.

[00:04:47] Speaker 01:
But regardless of that, I think that

[00:04:51] Speaker 01:
It was incumbent on the board to grapple with the implications of the predictability here in determining whether the reference to adjacent coils would disclose.

[00:05:02] Speaker 02:
If we agree with you on that, you've cited to Global IP.

[00:05:05] Speaker 02:
There, I think, there was a vacated rematch.

[00:05:08] Speaker 02:
Is that what we should do if we agree with you on predictability?

[00:05:11] Speaker 01:
I think that if the court is not inclined to sort of resolve the question of whether adjacent coils discloses the side by side as a matter of law, then yes, the proper course would be to vacate, as the court did in global IP holdings, and remain to the board to consider the analysis with the proper attention to the predictability of the technology.

[00:05:36] Speaker 04:
Let's talk about the three terminals.

[00:05:41] Speaker 04:
more or less standard terminals.

[00:05:43] Speaker 04:
But the third is a different kind of connection.

[00:05:47] Speaker 04:
How do you rationalize that all of these are?

[00:05:51] Speaker 04:
Do they have to be the same kind of terminal?

[00:05:54] Speaker 04:
Or is it sufficient if there's a connection?

[00:05:58] Speaker 01:
I think, Your Honor, that the key is it has to be a connection to external circuitry.

[00:06:05] Speaker 01:
The problem with real is that there are only two connections to external circuitry and real, which are the two connections to the bridge rectifier.

[00:06:16] Speaker 01:
And you can actually see this, I think, most clearly by looking at Samsung's own arguments.

[00:06:22] Speaker 01:
Because before the board, Samsung analogized Reel's antenna to the antenna that's depicted in figure 2A of the patent, which you can find at appendix 102.

[00:06:32] Speaker 01:
And Samsung analogized the capacitors C1 and C2 of the switch circuit in figure 2A to Reel's capacitor network.

[00:06:44] Speaker 01:
But if you look at figure 2A, the points on the coils that connect the coils to the switch circuit, which is part of the antenna, those are not denoted as terminals.

[00:06:56] Speaker 01:
You can see point 33, for example, which connects each of the coils to C1 and C2.

[00:07:04] Speaker 01:
That is not a terminal.

[00:07:05] Speaker 01:
It is described as, quote, a point which is an electrical junction between the first and second coils.

[00:07:12] Speaker 01:
And that's effectively what Samsung has mapped a third terminal to in Reel, which I think is just inconsistent with Reel's express disclosures, because Reel tells us where its terminals are.

[00:07:26] Speaker 01:
It uses the word terminal in one place.

[00:07:30] Speaker 01:
And that's in paragraph 26, which is in appendix 2200.

[00:07:33] Speaker 01:
And it does so to refer to the inputs to the bridge rectifier.

[00:07:38] Speaker 01:
And Reel makes clear that there are only two of those.

[00:07:40] Speaker 01:
And so what Real calls the ends of the coils that Samsung tried to map to the terminals, those are explicitly referred to as interconnection points, which are analogous to the electrical junction that is depicted, for example, in point 33.

[00:08:03] Speaker 04:
So that's the distinction that should be drawn, whether it's

[00:08:09] Speaker 01:
Yes, Your Honor, I think the distinction is whether it's an interconnection point within the antenna

[00:08:19] Speaker 01:
versus a point on the antenna that actually connects the antenna to external circuitry.

[00:08:25] Speaker 01:
So, for example, in figure 2A in the patent, the terminals are 34, 35, and 36.

[00:08:33] Speaker 01:
And those are the connections to an external electronic device, like, for example, a rectifier.

[00:08:39] Speaker 01:
And so in Reel, analogously, the terminals are the two connections between Reel's receiver antenna and the bridge rectifier 4.

[00:08:49] Speaker 01:
And those internal connection points, those are not terminals under the plain, ordinary meaning of the term.

[00:08:56] Speaker 02:
What about figure nine of the patent and the discussion?

[00:08:58] Speaker 02:
I think it's column 28, but the discussion of figure nine.

[00:09:02] Speaker 02:
Isn't that supportive of the way the board understood what a terminal is?

[00:09:08] Speaker 01:
I don't believe so, Your Honor, because if you look at figure nine,

[00:09:18] Speaker 01:
The terminals there are again denoted 34, 35, and 36.

[00:09:29] Speaker 01:
And those are extending outside of the antenna to the external electronic device.

[00:09:37] Speaker 02:
But in column 28, doesn't it explain that the

[00:09:42] Speaker 01:
common for the electrical connection point 148 151 52 can serve as the terminal Yes, yes, and I think that's correct that the connection points can serve as the terminal But what what makes them a terminal as opposed to merely a connection point is that they also connect to something external to the antenna which you can see

[00:10:10] Speaker 01:
35 36 and 34 they do they come off of those connection points and they connect to something else and the problem with real and you can see this I think if you turn to appendix 14 to 15 this is This is the board's decision the problem with real is that this connection point that Samsung mapped to the third terminal that's circled here in red and

[00:10:36] Speaker 01:
That doesn't actually go to anything that's external to the antenna.

[00:10:41] Speaker 01:
It just connects to the capacitor network, which is internal to Reel's receiver.

[00:10:48] Speaker 01:
What's circled in green and blue, the first and second terminals,

[00:10:53] Speaker 01:
Those do eventually get to the bridge rectifier.

[00:10:56] Speaker 01:
And so depending on how you draw the boxes, you might be able to say that those end up being antennas because they end up getting outside of the antenna itself.

[00:11:05] Speaker 01:
But this so-called third terminal, the junction point between L2 and L3, it never does that.

[00:11:11] Speaker 01:
And so it doesn't qualify as a terminal.

[00:11:17] Speaker 01:
I see that I'm close to my rebuttal time.

[00:11:19] Speaker 01:
If the panel has further questions, I'm happy to answer them.

[00:11:22] Speaker 01:
Otherwise, I'll reserve the balance of my time.

[00:11:26] Speaker 04:
All right.

[00:11:26] Speaker 04:
Let's hear from the other side.

[00:11:28] Speaker 04:
Thank you, Your Honors.

[00:11:32] Speaker 04:
OK.

[00:11:32] Speaker 04:
Mr. Bansal, are you ready?

[00:11:35] Speaker 00:
Good morning, Your Honors, and may it please the court.

[00:11:37] Speaker 00:
Let me begin by addressing the prior art dispute, as that is dispositive

[00:11:42] Speaker 00:
of all but two challenge claims across the two patents.

[00:11:45] Speaker 00:
The board made a factual finding that Reel discloses the claim terminals under the interpretation of that term offered by new current below.

[00:11:53] Speaker 00:
Therefore, there is no claim construction issue for this court to decide.

[00:11:57] Speaker 00:
Moreover, the board's finding on appendix page 25 that Reel's inductors L2 and L3 constitute an antenna

[00:12:07] Speaker 00:
renders moot the belated interpretation of external circuitry that New Current offers on appeal.

[00:12:12] Speaker 00:
Substantial evidence supports the board's finding.

[00:12:14] Speaker 00:
Let me explain.

[00:12:17] Speaker 00:
I want to start with the fact that while Dr. Baker, Samsung's expert, offered testimony on why Reel's interconnection points 1, 2, and 3 with the appended conductive material constitute terminals, New Currents Declaring did not rebut or disagree with the testimony.

[00:12:38] Speaker 00:
And the board noted that at appendix page 34.

[00:12:43] Speaker 00:
I heard New Currents Council talk about the fact that the capacitor network is not external circuitry.

[00:12:53] Speaker 00:
Dr. Baker here is the only declarant who offered testimony stating that the capacitor network is indeed external circuitry.

[00:13:02] Speaker 00:
And the board cited that.

[00:13:04] Speaker 00:
But I think we should take a look at appendix page 314 and 315.

[00:13:15] Speaker 00:
The coils L2 and L3, they actually constitute the antenna.

[00:13:27] Speaker 00:
So your honor, if you look at figure three of real that is reproduced on appendix page 314, there's a capacitor network C2A, C2Q, C2P.

[00:13:37] Speaker 00:
By its construction, Newcurrent wants to say that is not external circuitry because that network is not external to the antenna.

[00:13:46] Speaker 00:
But what Newcurrent ignores is the antenna in real is undisputedly L2 and L3.

[00:13:54] Speaker 00:
If you look at the analysis that Samsung provided in its petition at the bottom of page 314, Samsung said the two inductor coils form a receiver coil.

[00:14:04] Speaker 00:
And then on the next page, Samsung said,

[00:14:06] Speaker 00:
a person of ordinary school in the yard would have understood that such a receiver coil is an antenna.

[00:14:13] Speaker 00:
And the board on Appendix Page 25 stated, antenna, that is a receiver coil.

[00:14:19] Speaker 00:
So the claim construction issue here is moot because

[00:14:24] Speaker 00:
that the capacitor network is external to the antenna under new current interpretation that it offers an appeal.

[00:14:31] Speaker 00:
Unless there are any questions, I would like to move on to the written description issue.

[00:14:35] Speaker 03:
Will you address for a minute, just address the arguments that were made about figure nine

[00:14:41] Speaker 03:
the patent and whether those that disclosure it goes in column 28 about that shows that those terminals or those connection points could be terminal so there was an explanation by your adversary about that I'd like to address it for me

[00:14:57] Speaker 00:
Your Honor, the way we read that passage and the way the board read that passage is a terminal is simply an interconnection point with appended conductive material that allows the connection, the coils to be connected to other circuitry.

[00:15:14] Speaker 00:
And I think that's all that column 20 says.

[00:15:18] Speaker 00:
It says in an embodiment, terminal leads 154, 156, 158,

[00:15:24] Speaker 00:
may be attached to these connection points to create antenna terminals.

[00:15:29] Speaker 03:
So that is kind of an argument going to, you know, a terminal doesn't have to be connected to external circuitry.

[00:15:35] Speaker 03:
But the alternative argument is that if you look at figure three of real, it discloses that anyway.

[00:15:41] Speaker 03:
Do I understand that correctly?

[00:15:42] Speaker 03:
Thank you.

[00:15:45] Speaker 00:
Unless your honors have any questions, I would like to turn to the written description issue.

[00:15:51] Speaker 00:
The board made a factual finding, supported by substantial evidence, that the inventor did not have possession of the claimed side-by-side coil arrangement.

[00:15:59] Speaker 00:
This side-by-side coil arrangement was added by New Current on the eve of allowance, apparently to cover Samson's then existing commercial products.

[00:16:08] Speaker 00:
But this 11th-hour amendment to the claims creates conflict with the specification, which the board grappled with because the

[00:16:16] Speaker 00:
board found that the specification only discloses concentric coils, and which New Current had repeatedly told the patent office was critical to the invention, as Judge Stoll noted.

[00:16:27] Speaker 00:
That's why we have this dispute, and that's why we have this appeal.

[00:16:30] Speaker 00:
Let me explain.

[00:16:31] Speaker 03:
How do you respond to the point about how the board should have considered the predictability?

[00:16:35] Speaker 03:
I mean, there was only two possible embodiments, concentric or side by side, and they should have considered that.

[00:16:43] Speaker 00:
Your Honors,

[00:16:44] Speaker 00:
The board considered the record as a whole.

[00:16:48] Speaker 00:
The board considered oral argument on this issue.

[00:16:50] Speaker 00:
That's at appendix page 599604.

[00:16:53] Speaker 00:
The board was simply unconvinced that the inventor had possession of the full claim scope of claim one.

[00:16:58] Speaker 00:
Having said that.

[00:17:01] Speaker 00:
Predictability is not really relevant here, Your Honor, for three reasons.

[00:17:06] Speaker 00:
First, predictability cannot be used as an excuse for the lack of disclosure of an explicitly recited claim limitation.

[00:17:14] Speaker 00:
Here, the way the claim is structured, it says one of A and B. It's a claim reciting a list.

[00:17:20] Speaker 00:
And it's black letter law that each element of that list has to be in the specification, has to be disclosed in the specification.

[00:17:26] Speaker 00:
The power OAS case that we cited says all claim limitations must be in the specification.

[00:17:33] Speaker 00:
So if the claimants had one of copper and aluminum, both copper and aluminum have to be in the specification.

[00:17:41] Speaker 00:
There's no issue about predictability there that can save the patentee if both elements of the claim are not or of that list are not in the specification.

[00:17:50] Speaker 00:
Here, everyone agrees that the claim recites two options, concentric

[00:17:56] Speaker 00:
and side by side.

[00:17:57] Speaker 00:
And the board made a factual finding that is entirely to deference or appeal that the side by side coil arrangement that is an explicit limitation of the claim is not in the specification.

[00:18:07] Speaker 00:
Second, predictability is only really relevant in a situation where we have- What's your answer?

[00:18:17] Speaker 04:
I was trying to interrupt because I do want to ask you.

[00:18:20] Speaker 04:
Well, what's your answer to all of the usages of adjacent in a specification?

[00:18:25] Speaker 00:
Your Honor, I will get to that.

[00:18:27] Speaker 00:
But I just wanted to, if I may, just address Judge Stoll's point earlier about criticality.

[00:18:33] Speaker 00:
Because if you look at INRE Global IP Holdings, this court said that INRE Peters, which held that criticality

[00:18:47] Speaker 00:
So if the disclosed species is critical to the invention, you don't really consider predictability.

[00:18:53] Speaker 00:
And here, you have evidence throughout the specification, as Judge Stoll noted, that the inventions about this compact antenna design, all things being equal.

[00:19:04] Speaker 00:
If you have two coils, and if you place them side by side versus concentric,

[00:19:08] Speaker 00:
the concentric arrangement is going to give you the more compact design.

[00:19:12] Speaker 00:
In fact, if you look at page 32 of New Current's blue brief, they say over there the concentric claim

[00:19:21] Speaker 00:
The concentric coil arrangement is not only more compact, but it's also more technologically advanced.

[00:19:27] Speaker 00:
That is a clear recognition of the criticality of the concentric coil arrangement.

[00:19:32] Speaker 00:
And that's why the board need not even have to consider predictability.

[00:19:35] Speaker 00:
Now, to Judge Newman's question about adjacent, Your Honor, context matters.

[00:19:42] Speaker 00:
And as Judge Stone noted,

[00:19:44] Speaker 00:
The board looked at the context of adjacent as used when describing adjacent coils.

[00:19:51] Speaker 00:
And in that context, the inventor only had possession of a concentric coil arrangement.

[00:19:59] Speaker 00:
And that's a factual finding that the board made, looking at all the citations Newcurrent provided to it, the competing expert testimony.

[00:20:08] Speaker 00:
That's a factual finding that is entitled to deference and appeal.

[00:20:11] Speaker 00:
And I would also like to note

[00:20:14] Speaker 00:
Even Newcurrent agrees that the term adjacent cannot be looked at in a vacuum.

[00:20:20] Speaker 00:
It is context-dependent.

[00:20:21] Speaker 00:
And this was Newcurrent's argument to the board on Appendix Page 597, Your Honors.

[00:20:27] Speaker 00:
Newcurrent said that

[00:20:33] Speaker 00:
The term adjacent, while it may generally mean next to, to determine its exact meaning, its precise meaning, you have to look at context.

[00:20:41] Speaker 00:
The board looked at that context, looked at the competing testimony, reviewed the entirety of the disclosure, and made a factual finding that the inventor did not have possession of the full scope of claim one.

[00:20:54] Speaker 00:
Unless your honors have any other questions.

[00:20:57] Speaker 02:
I do have one.

[00:20:58] Speaker 02:
There is, I think, one reference to adjacent

[00:21:02] Speaker 02:
In connection with coils, where the inventor says such as, if that's correct, what else could we have meant, particularly in light of the predictability of the arc here, other than such as concentric and side by side?

[00:21:17] Speaker 00:
So I think more than one reference is to such as.

[00:21:24] Speaker 00:
In the context of coils?

[00:21:26] Speaker 00:
In the context of coils, exactly.

[00:21:29] Speaker 00:
So maybe the easiest way to see if the board erred or did not err, we can just replace adjacent coils in that sentence.

[00:21:41] Speaker 00:
And I think this is at column 19.

[00:21:44] Speaker 00:
I think we should look at this together.

[00:21:46] Speaker 00:
Column 19, line 61 through 63.

[00:21:50] Speaker 00:
If we were to replace adjacent first and second inductor coils with concentric first and second inductor coils,

[00:21:56] Speaker 00:
such as coils 76, 78, that sentence would actually make sense.

[00:22:02] Speaker 00:
So what the board said was, such as is simply describing examples of concentric coils, and the specification has other examples of concentric coils.

[00:22:10] Speaker 00:
For instance, you could have more than two concentric coils, not just the two that are described in, for instance, figure three or figure two.

[00:22:20] Speaker 00:
Unless your honors have any other questions, I will give the court back its time.

[00:22:26] Speaker 04:
Any more questions for Towson?

[00:22:28] Speaker 00:
No, thank you.

[00:22:30] Speaker ?:
Okay, good.

[00:22:31] Speaker 04:
We will hear a bell then from Mr. Millican.

[00:22:36] Speaker 01:
Thank you, Your Honors.

[00:22:36] Speaker 01:
Just a couple of brief points in rebuttal.

[00:22:39] Speaker 01:
I'll pick up with written description, since that's where my friend left off.

[00:22:44] Speaker 01:
Samsung does not point to anywhere in the board's decision where it considered the predictability of the technology, because Samsung cannot do so.

[00:22:51] Speaker 01:
The board's only mention of predictability was its legally incorrect statement that predictability is a factor that it merely may consider.

[00:23:00] Speaker 01:
My friend also argued that predictability isn't really relevant here because we have a claim that discloses sort of A or B. But this is effectively a genus claim.

[00:23:11] Speaker 01:
It's a genus of two because we have undisputed record evidence that there are only two possible arrangements, concentric and side by side.

[00:23:20] Speaker 01:
And given that, predictability is decidedly relevant.

[00:23:25] Speaker 01:
My friend also mentioned the criticality point.

[00:23:29] Speaker 01:
I disagree that the smaller footprint is a critical aspect of this invention such that it renders predictability irrelevant.

[00:23:39] Speaker 01:
I would say again that the critical aspect of the invention is this ability to selectively connect three terminals.

[00:23:47] Speaker 01:
Even putting all that aside, that is not the analysis the board did.

[00:23:52] Speaker 01:
The board did not say, well, New Current has made these arguments about predictability, but we don't think they're relevant because we find as a factual matter

[00:24:02] Speaker 01:
that the small footprint was critical to the invention.

[00:24:07] Speaker 01:
And so the patentee necessarily meant just the concentric arrangement.

[00:24:12] Speaker 01:
If that had been the board's analysis, we might be having a different argument.

[00:24:16] Speaker 01:
But that's not what the board found.

[00:24:18] Speaker 01:
And so at minimum, I think that the proper remedy would be to vacate the board's decision and to remand for consideration of the written description issue with proper attention to predictability.

[00:24:31] Speaker 01:
On obviousness, my friend argued that the claim construction dispute here is effectively moot because the board applied our proposed construction.

[00:24:43] Speaker 01:
That's not correct.

[00:24:44] Speaker 01:
The board said quite clearly at appendix 89 that in its view,

[00:24:49] Speaker 01:
What made something a terminal was just a connection to circuitry that was external to the coil as opposed to external to the antenna.

[00:24:59] Speaker 01:
That's precisely the claim construction error that we are urging on appeal.

[00:25:04] Speaker 01:
In order to be a terminal, a point has to connect to something outside of the antenna.

[00:25:11] Speaker 01:
My friend also argued that the antenna in Reel comprises L2 and L3, so just the coils and nothing else.

[00:25:21] Speaker 01:
That's not correct, and the board did not make any such finding.

[00:25:25] Speaker 01:
The board found that Reel had three terminals based on its erroneous conclusion that all you have to do to be a terminal is to connect to something outside of the coil.

[00:25:35] Speaker 01:
And I would again point to Samsung's mapping of Reel's antenna to the figure 2A antenna, because that shows that the antenna in Reel is not just L2 and L3.

[00:25:48] Speaker 01:
The capacitors to which Samsung mapped Reel's matching network

[00:25:54] Speaker 01:
are indisputably part of the claimed antenna.

[00:25:58] Speaker 01:
The patent says this explicitly.

[00:26:00] Speaker 01:
That is a switch circuit, and it is a switch circuit that is one of the components of the antenna.

[00:26:06] Speaker 01:
And so if you follow that mapping, which Samsung itself urged, then you necessarily must conclude, I think, that the interconnection points at the ends of Reel's coils do not qualify as terminals.

[00:26:20] Speaker 01:
If the court has further questions, I'm happy to answer them.

[00:26:22] Speaker 01:
Otherwise, I'll cede the balance of my time.

[00:26:25] Speaker 04:
Any questions for Council?

[00:26:27] Speaker 02:
No.

[00:26:27] Speaker 02:
No.

[00:26:28] Speaker 01:
Thank you.

[00:26:28] Speaker 01:
Okay.

[00:26:29] Speaker 04:
Thank you.