[00:00:00] Speaker 03:
Mr. Green's phone, please proceed.

[00:00:10] Speaker 00:
Thank you, Your Honor, and good morning, Your Honors.

[00:00:14] Speaker 00:
May it please the Court?

[00:00:15] Speaker 00:
The Court has two pathways toward reversal in the first case this morning, 1305.

[00:00:21] Speaker 00:
The first is claim construction, because if Zaxcom is right that the original claims

[00:00:27] Speaker 00:
that the original claims do not embrace mere multi-track recording, then the board's patentability conclusion on the substitute claims applies and the court may reverse based on that.

[00:00:39] Speaker 00:
But today, I'm going to focus my role.

[00:00:40] Speaker 03:
Well, it looks like the board did a very thorough job here.

[00:00:45] Speaker 03:
It distinguished between claims that were not limited to drop out.

[00:00:53] Speaker 03:
And hence, it concluded it did not have a nexus with long-felt need in the street.

[00:01:00] Speaker 03:
praise and claims that were limited to the dropout and hence were entitled to a nexus.

[00:01:08] Speaker 03:
Why don't we respect that and consider they did a sound job in making distinctions?

[00:01:16] Speaker 00:
Well, I'm with you Judge Lurie up to the point where maybe there's an assumption that the claim construction was correct.

[00:01:23] Speaker 00:
If our claim construction is correct, that the original claims are limited to dropout repair,

[00:01:28] Speaker 00:
then we get the benefit of all the substitute claim analysis.

[00:01:32] Speaker 00:
That's our contention.

[00:01:35] Speaker 00:
And that particular argument has to do with English grammar.

[00:01:37] Speaker 00:
It's fully briefed.

[00:01:39] Speaker 00:
The thing on the right-hand side of the combine and the thing on the left-hand side of the combine have to come from the same audio.

[00:01:48] Speaker 00:
That's our contention.

[00:01:49] Speaker 00:
But today, Your Honors, I'd like to focus on the other pathway for reversal.

[00:01:54] Speaker 02:
And can I just understand, when you mean from the same audio, you mean from the same local audio device pickup of sound?

[00:02:08] Speaker 00:
That's right, Your Honor.

[00:02:09] Speaker 00:
We call it the same sound waves in the briefing, here and below.

[00:02:14] Speaker 02:
And what is your best, I guess, what did you call it, English language?

[00:02:21] Speaker 02:
linking argument to come to that conclusion that it has to be just the sound that I'm getting, not the sound that you're getting that then gets combined with the sound that I already sent to the remote reporter.

[00:02:40] Speaker 00:
Sure.

[00:02:41] Speaker 00:
It really is the ligatures and connections in the claim, what I call patentees, which is on one side of the word combined at the end of the claim, you have local,

[00:02:51] Speaker 00:
audio data on the other side of the combined word at the end of the claim, you have remotely recorded audio data.

[00:02:57] Speaker 00:
And then if you trace those antecedent bases upward into the claim, they both source from the language in the preamble, locally generated audio.

[00:03:09] Speaker 00:
And it would take some time to sort of walk through each and every ligature, of course.

[00:03:14] Speaker 00:
So if I may, Your Honor, proceed.

[00:03:18] Speaker 00:
So assume the board's construction was right.

[00:03:21] Speaker 00:
that Zaxcom doesn't get the benefit of this narrowing for the original claims.

[00:03:27] Speaker 00:
But Zaxcom then wins for claims one through 11 based on the error in the no nexus finding.

[00:03:33] Speaker 00:
And nexus is, nexus based on industry praise, your honors, is binary of the tort law.

[00:03:40] Speaker 00:
It is either there or it is not.

[00:03:43] Speaker 00:
And if it is, all of the weighing happens against an obviousness theory later in the analysis.

[00:03:50] Speaker 00:
So the question for Nexus is whether the objective evidence is both reasonably commensurate with the scope of the claims.

[00:03:57] Speaker 00:
And under this standard.

[00:03:59] Speaker 03:
Let's look at the meaning of the claim.

[00:04:01] Speaker 03:
This is in a wherein clause.

[00:04:05] Speaker 03:
Is that simply a result or is it a structural step in the method?

[00:04:13] Speaker 00:
Wherein is different from whereby.

[00:04:18] Speaker 00:
is defining structure or defining functions or features in the claim.

[00:04:23] Speaker 00:
So whereby would be a different case entirely, but wherein is... You're saying it's a step.

[00:04:30] Speaker 03:
It's a method claim, so there isn't structure, is there?

[00:04:34] Speaker 00:
Well, there's a method claim 12, and then apparatus claim 1.

[00:04:41] Speaker 00:
I mean, either way you look at it, the wherein clause at the end is further definitional.

[00:04:47] Speaker 00:
for whatever is going on in the claim.

[00:04:52] Speaker 00:
But back to Nexus, Your Honors, this case has apex award industry praise.

[00:04:57] Speaker 00:
The board called it strong when addressing the substitute claims.

[00:05:01] Speaker 00:
You've seen the technical achievement award from the Motion Picture Academy.

[00:05:05] Speaker 00:
That's the Oscar.

[00:05:07] Speaker 00:
You've seen the technology and engineering award from the Television Academy.

[00:05:11] Speaker 00:
That's the Emmy.

[00:05:13] Speaker 00:
The main point on appeal, Your Honors, is that these awards were not for advertising, they were not for workmanship, they were not for ornament, they were technology awards, and they're from Zaxcom's peers and competitors phrasing the 900 series design.

[00:05:29] Speaker 02:
Can I just ask you this?

[00:05:32] Speaker 02:
And my assumptions may not be right.

[00:05:35] Speaker 02:
But why doesn't it, in fact, matter a very great deal if you're wrong about the claim construction and if the board is right about the claim construction?

[00:05:46] Speaker 02:
So assume you have a claim that covers embodiments A and B, and there's lots of praise for B.

[00:05:58] Speaker 02:
Why does that automatically tell you that a claim, or not automatically tell you, why does that justify a presumption of nexus for a claim that covers A, for which there's no praise at all?

[00:06:15] Speaker 00:
Well, the short answer, Judge, is that's not our case, because we have the Emmy materials at 4272 and 40, well, that's Oscar.

[00:06:24] Speaker 00:
Emmy is 4304, which calls out that

[00:06:27] Speaker 00:
It's, quote, not for a single component before the system as a whole.

[00:06:31] Speaker 02:
So system as a whole.

[00:06:33] Speaker 02:
But if the claim offers sort of standard variety multi-tracking, taking a bunch of different local records and putting them on parallel tracks, and there's no place for that, then why should that place for something else affect the obvious analysis of something that is

[00:06:56] Speaker 02:
my claim construction within the claim?

[00:06:59] Speaker 00:
It perhaps might, your honor, at the rebuttal stage of the analysis of nexus and presumptions of nexus.

[00:07:08] Speaker 00:
But here we're at the presumption stage.

[00:07:11] Speaker 00:
This is the short path that the law offers the patentee, where what you show is that the claim is an embodiment, or the product is an embodiment of the claim.

[00:07:21] Speaker 00:
The product was praised.

[00:07:23] Speaker 00:
The one exception, which I'm sure we'll discuss today, is coextensiveness.

[00:07:28] Speaker 00:
But coextensiveness is a situation where the claim coverage is for a, quote, small component.

[00:07:35] Speaker 00:
That's the Henny Penny case.

[00:07:36] Speaker 00:
If the claim coverage is for a small component, then you don't get the presumption of nexus.

[00:07:42] Speaker 00:
But if the claim is for the whole system, you do.

[00:07:45] Speaker 00:
And that's very clear in the case law, particularly Henny Penny.

[00:07:51] Speaker 00:
Back to the awards, Your Honor, and the praise.

[00:07:55] Speaker 00:
You know, last Friday's decision in quantity systems shows that Zaxcom did all it needed to do to get the presumption.

[00:08:02] Speaker 00:
And the evidence shows that the 307 patent covers the 900 series system.

[00:08:07] Speaker 00:
No one disputes that on appeal.

[00:08:09] Speaker 00:
And if we get into questions of co-extensiveness, the result is the same, because the claim coverage is for a whole system.

[00:08:16] Speaker 00:
The praise, especially 4304 of the appendix, talks about the whole system.

[00:08:21] Speaker 00:
And certainly, you know, it's certainly correct that there are call-outs of additional things.

[00:08:29] Speaker 00:
But that's when I get to go to the Fox factory analysis, your honor.

[00:08:36] Speaker 00:
And let's say Fox factory is good law.

[00:08:38] Speaker 00:
I'm assuming that for my argument today.

[00:08:41] Speaker 00:
In the Fox factory analysis, the co-extendedness limitation or exception is expanded somewhat to also exclude the benefit

[00:08:51] Speaker 00:
of critical unclaimed features that have a material impact on the functioning of the system.

[00:08:58] Speaker 00:
So let's break that down.

[00:09:02] Speaker 00:
Critical unclaimed features, there is no argument before the board from Lectrasonics that any of the call outs below where the ME materials say it was the whole system that got the award were for quote unquote critical unclaimed features.

[00:09:17] Speaker 00:
And in fact, there's a second exception that goes, well, not exception, but a second way or pathway for Electro's rebuttal to undermine the presumption that I just talked about.

[00:09:28] Speaker 00:
That would be to show that the claim combination is merely readily known in the prior arts.

[00:09:34] Speaker 00:
And that won't work either for Electro because the Rambus case, Rambus-Buray, 731 F3, 1257,

[00:09:41] Speaker 00:
said that this legal standard requires that the objective evidence to have arisen exclusively from prior art features.

[00:09:48] Speaker 00:
And that's impossible because the whole combination is, on this record, undisputedly novel as a combination.

[00:09:55] Speaker 00:
And of course, the future question for analysis is whether it's also obvious, and we contend it's not.

[00:10:02] Speaker 00:
So, Your Honors, the board's no on Nexus should have been a yes.

[00:10:05] Speaker 00:
Again, it's binary, weighing happens later,

[00:10:09] Speaker 00:
and the board lacks substantial evidence for its no-nexus finding, in view of at least the award materials showing that the whole system earned Zach's comm its apex awards.

[00:10:18] Speaker 00:
But the board did get it right to call the objective evidence strong when it studied it.

[00:10:23] Speaker 00:
And that's why this court should reverse on the original claims.

[00:10:25] Speaker 00:
And I'd like to reserve the rest of my time for rebuttals.

[00:10:28] Speaker 03:
We will do that, Mr. Bell.

[00:10:33] Speaker 01:
Thank you.

[00:10:33] Speaker 01:
Good morning, Your Honors.

[00:10:34] Speaker 01:
May it please the court, Corey Bell for across the panel,

[00:10:39] Speaker 01:
I'll start with Nexus where we just left off, in particular their 28-J letter.

[00:10:44] Speaker 01:
They make this claim that in the proceedings before, they did the exact same analysis where they had their expert directly mask the product to the claims.

[00:10:55] Speaker 01:
But we can look directly at the only Nexus analysis that was presented by Zaxcom below, and that's APTX 396.

[00:11:03] Speaker 01:
And all that does is have a statement that there is a strong nexus between the objective indica and the issued and substitute claims of the 307 patent, including those that were found to be anticipated.

[00:11:14] Speaker 01:
Then the expert simply goes on to state the language of the claim, no comparison between the claim language and the ethics.

[00:11:22] Speaker 01:
So that's why this is not like the controversy.

[00:11:25] Speaker 01:
And our real issue with this case here is what happened after the fact.

[00:11:29] Speaker 01:
And this was the board's decision to

[00:11:31] Speaker 01:
stand in the patent owner's shoes and make an argument for the first time in the final decision relating to whether or not there was nexus relating to the replacing elements of the claim?

[00:11:42] Speaker 03:
Mr. Bell, assuming the claim construction is correct and that it encompasses both multi-track and dropout, that's in terms of co-extensiveness, those are only two embodiments.

[00:12:01] Speaker 03:
And so do we not consider a nexus when more than one embodiment has a nexus?

[00:12:14] Speaker 03:
I mean, here there are only two.

[00:12:15] Speaker 03:
It's not like you get a great big broad claim with unlimited number of embodiments and only one of them has a nexus.

[00:12:24] Speaker 03:
And it's not like, I don't think it's like something is missing

[00:12:29] Speaker 03:
or something is really additive, tell us why there should be no Nexus when there are just two embodiments.

[00:12:40] Speaker 01:
Yes, Your Honor.

[00:12:41] Speaker 01:
And first, I think there's a clear point to make here, which we did dispute that there was essential features missing.

[00:12:47] Speaker 01:
So what Zaxcon was praised for and claimed it was praised for below was having a wireless transmitter with integrated report

[00:12:54] Speaker 01:
That is not what the claims require.

[00:12:56] Speaker 01:
In fact, the original claim, claim one does not even include a wireless transmitter.

[00:13:00] Speaker 01:
That was added in the motion tool net.

[00:13:03] Speaker 01:
So all of this discuss of wireless transmission and its benefits there have nothing to do with the original claims.

[00:13:10] Speaker 01:
The other issue is what the board was trying to do was trying to help facts come out.

[00:13:14] Speaker 01:
Because all of the elements that relate to the local recording device was all in the primary reference struct.

[00:13:22] Speaker 01:
So the issue is that that local recording device had the capability of doing many things.

[00:13:27] Speaker 01:
It could be used to do multi-track.

[00:13:30] Speaker 01:
It could be used to do dropout repair.

[00:13:32] Speaker 01:
That really wasn't the invention.

[00:13:34] Speaker 01:
The invention was having a specific local audio device.

[00:13:37] Speaker 01:
And the problem for Zaxcom is that the elements in the claims that relate to that also relate directly to the primary reference.

[00:13:45] Speaker 01:
So when we're talking about secondary considerations and concerns of hindsight, there's no hindsight concern.

[00:13:50] Speaker 01:
Because we're not reading anything into the primary reference because it's all there.

[00:14:00] Speaker 01:
And then just briefly returning to my issues with what the board did.

[00:14:04] Speaker 01:
One, it was long for them to stand in patent owner's shoes because it was patent owners better than to carry it.

[00:14:10] Speaker 01:
But also, they did this for the first time in the final decision.

[00:14:14] Speaker 01:
So we did not have the opportunity to respond.

[00:14:17] Speaker 01:
Additionally, this case was pre-Fox factory and the PTO found a presumption of nexus.

[00:14:22] Speaker 01:
And their argument for why that's still fine is really interesting to me.

[00:14:27] Speaker 01:
The PTO's argument is that this is a harmless error because in two later cases, revolving, relating to two different patents in the names of different scopes, the board reached the same outcome on the same evidence and the same argument.

[00:14:41] Speaker 01:
But that's exactly what the court criticized in Fox Factory, is that you shouldn't be looking at the same evidence and the same arguments to define multiple claims of different scope across different patents, all to be patent eligible over that same evidence.

[00:14:54] Speaker 01:
And the issues don't just appear in the Nexus analysis.

[00:14:59] Speaker 01:
In particular, if we go to long-fell need, which is what the board highlighted as its first evidence of strong Nexus, the first step of proving Nexus requires

[00:15:09] Speaker 01:
that there be a long felt need based on the date when the problem could be solved or identified and the efforts made to solve that problem.

[00:15:18] Speaker 01:
The board reached the conclusion that there was no evidence of the date when the problem could be solved or identified and the efforts were made to solve the problem.

[00:15:27] Speaker 01:
So the board concluded that under the legal test, we don't have what we need to reach long felt needs.

[00:15:32] Speaker 01:
The PTO's response is that substantial evidence supports the board's conclusion.

[00:15:37] Speaker 01:
The problem is that substantial evidence

[00:15:39] Speaker 01:
the board's conclusions, that supports the finding that there was, in fact, no long-held need under the legal test.

[00:15:51] Speaker 01:
No, Your Honor.

[00:15:53] Speaker 03:
We will save your time.

[00:15:56] Speaker 03:
There's still time for the PTO.

[00:15:59] Speaker 04:
Thank you, Your Honor.

[00:16:00] Speaker 04:
May it please the court?

[00:16:02] Speaker 04:
The parties have well covered the claim construction and factual disputes here.

[00:16:07] Speaker 04:
And as the court knows, we believe these intensely factual determinations by the board are supported by substantial evidence.

[00:16:14] Speaker 04:
So I just wanted to make a couple of quick points.

[00:16:17] Speaker 04:
First, there's been a lot of debate about the burden shifting and nexus framework.

[00:16:23] Speaker 04:
And fundamentally, the framework requires exactly what the board did in all three of these cases, which is to see whether the evidence shows a close enough relationship between the claimed novel invention

[00:16:35] Speaker 04:
and the praise from the industry.

[00:16:38] Speaker 04:
All three cases, or I'm sorry, all of this court's cases on Nexus emphasize that that inquiry depends on the particular facts and circumstances in the case, facts and circumstances that the board here analyzed in depth.

[00:16:56] Speaker 04:
Second, many of the cases that the private parties rely on like Apple versus Samsung, WBIP, Classco,

[00:17:06] Speaker 04:
and Brown and Williamson all wind up affirming the fact finder on secondary considerations, even when they criticize the lower tribunal burden shifting framework.

[00:17:18] Speaker 04:
And the fact finding in the first instance is the predominant factor.

[00:17:22] Speaker 04:
Finally, I just wanted to address the point.

[00:17:27] Speaker 02:
Can I just ask you, I guess I'm a little confused.

[00:17:32] Speaker 02:
hearing you incorrectly in saying, nevermind all this presumption business, it's all just a question of fact-finding.

[00:17:40] Speaker 02:
I mean, that may be a sound way to run the railroad, but it's not really our current way, is it?

[00:17:46] Speaker 04:
No, no, the presumption and burden shifting is important.

[00:17:51] Speaker 04:
And I'm not trying to downplay that.

[00:17:53] Speaker 04:
And it's about sort of who has to provide evidence at what point.

[00:17:58] Speaker 04:
And I think the board addressed that correctly by saying,

[00:18:02] Speaker 04:
there was by starting with the presumption analysis and moving on to the nexus analysis.

[00:18:10] Speaker 04:
And this court's cases address those sort of, there's a little bit of variation in how the case law addresses which part is the presumption and which part is the ultimate nexus question.

[00:18:25] Speaker 04:
On the presumption question, it's clear that it requires that the claims both embody

[00:18:32] Speaker 04:
the product both embody the invention and be coextensive with the invention.

[00:18:40] Speaker 04:
That test is in cases like Henny Penny, also the Brennan-Williamson case.

[00:18:50] Speaker 04:
And I think that makes it clear that the coextensiveness analysis isn't exactly the same thing as the embody analysis or the embody question.

[00:19:00] Speaker 04:
Daxcom is trying to say all it has to do is embody the claimed invention, but the co-extensiveness has to do some work too in order to get the presumption.

[00:19:10] Speaker 04:
And then the ultimate nexus question depends on sort of how close, there's just a lot of weighing of evidence that is different in every case.

[00:19:22] Speaker 02:
So why do you think that the original claims did not meet the co-extensive tests and the substitute claims did?

[00:19:37] Speaker 04:
Well, certainly the original claims are broader and cover the multitrack embodiment.

[00:19:43] Speaker 04:
And the multitrack embodiment is exactly what is in strub, right?

[00:19:49] Speaker 04:
So you have prior art.

[00:19:50] Speaker 04:
that does exactly the thing, that the claims are broad enough to cover.

[00:19:55] Speaker 04:
So you've got, and then when you look at the dropout embodiment, it's different from what the prior art does and it's the thing that was praised.

[00:20:06] Speaker 04:
So the board focused on that as well, right, that the praise was heavily focused on repairing dropouts.

[00:20:15] Speaker 04:
So to grant,

[00:20:18] Speaker 04:
the nexus and find the claims non-obvious when they are broad enough to cover a different embodiment that's in the prior art seems like a too big a stretch of the nexus analysis or of the secondary considerations analysis.

[00:20:37] Speaker 02:
Did the board conclude on the original claim that even if there were a presumption

[00:20:43] Speaker 02:
that these objective indicia could not outweigh, let's call it the prima facie case of obviousness of the multi-track embodiment and therefore of the claims.

[00:21:01] Speaker 04:
I think that is an accurate way to read the board's opinion.

[00:21:06] Speaker 04:
The board did not, so looking at the original claims in this,

[00:21:13] Speaker 04:
In this first case, the board didn't talk about the presumption one way or the other.

[00:21:18] Speaker 04:
The board talked about the presumption in the context of the amended claims and then talked about it more in the later case after Fox Factory had issued from this court and sort of emphasized the process of the burden shifting analysis.

[00:21:37] Speaker 04:
But I think they,

[00:21:41] Speaker 04:
The analysis on the original claims was just that the claims are so broad that they cover something that isn't what was praised and something that was in the prior art.

[00:22:00] Speaker 03:
Thank you, Ms.

[00:22:01] Speaker 03:
Sofen.

[00:22:02] Speaker 03:
Mr. Greenspoon, we'll give you three minutes for a bottle.

[00:22:07] Speaker 00:
Thank you, your honor.

[00:22:08] Speaker 00:
Uh, and just to answer the question you just asked, the board actually gave zero weight to secondary considerations for the obviousness analysis on the original claims.

[00:22:18] Speaker 00:
So that's, uh, I think a more complete answer than what you just heard.

[00:22:22] Speaker 02:
And can I just double check something that the weighing is a matter of law, which we can do.

[00:22:28] Speaker 00:
The final weighing with, if you're looking at the Emmy and the Oscar and its program materials, et cetera,

[00:22:34] Speaker 00:
And comparing that to the obviousness case, yes, that's an issue of law not performed by the board for the original claims at all, because they decided to give it a zero instead of a one for the binary nexus finding.

[00:22:48] Speaker 03:
It also looks like it has a lot of weight.

[00:22:53] Speaker 00:
They're pretty heavy when you pick them up, Judge.

[00:22:55] Speaker 00:
I agree.

[00:22:56] Speaker 00:
And Your Honors, we're not trying to evade the court's sentence requirement.

[00:23:00] Speaker 00:
I think you might have heard that suggested.

[00:23:04] Speaker 00:
For the presumption question and answer, we understand and embrace that there is a co-extensiveness analysis baked into that.

[00:23:12] Speaker 00:
But the co-extensiveness analysis, properly construed under Henny Penny, Rambus, just a variety of cases, is that if it's a component, if the claim coverage is not the wide outdoors, but is just a tiny, small component,

[00:23:29] Speaker 00:
then you don't give the presumption.

[00:23:31] Speaker 00:
That's the co-extensiveness exception when otherwise we've met, you know, the Apple v. Samsung on bunk standards, WVIP, et cetera.

[00:23:41] Speaker 00:
So moving on, just very quickly, evidence of claim coverage over the 900 series.

[00:23:46] Speaker 00:
Very surprised to hear that that's an issue today at Oral Arguments.

[00:23:49] Speaker 00:
But I would refer your honors not only to Appendix 396, which is a patent owner response,

[00:23:55] Speaker 00:
but also expert testimony at appendix 3051 to 52, and the inventor's testimony at 3102 to 03.

[00:24:03] Speaker 00:
These all validated, verified claim coverage over the thing that was praised by the various academies.

[00:24:10] Speaker 00:
And just a couple final points.

[00:24:13] Speaker 00:
I'm going to, with respect, I'm going to call it the irony of irony that we just heard from Mr. Bell, that the,

[00:24:22] Speaker 00:
thrust of their cross appeal is the due process notice question.

[00:24:27] Speaker 00:
And the reason for that is in the opening blue, the opening red brief, we didn't see anything about this.

[00:24:33] Speaker 00:
There's no citation of magnitude.

[00:24:35] Speaker 00:
It's a fully fleshed out argument in the reply brief.

[00:24:37] Speaker 00:
I'll grant him the cross appeal reply, but it's not in the opening brief.

[00:24:40] Speaker 00:
And in any case, what's the outcome of his argument, if he were correct about it, it's that he gets to put in a fourth brief at the board in addition to the other three,

[00:24:52] Speaker 00:
to say exactly the same things he's saying that he's always said, which is talking about unclaimed features and that the claims just cover the prior art.

[00:25:01] Speaker 00:
Finally, last very last point on long felt need.

[00:25:03] Speaker 00:
The board did identify the year 2005 as a, as a hard place to frame its, its analysis and then gave it little weight for reasons that are in the record, which we don't need to go into.

[00:25:15] Speaker 00:
Thank you again.

[00:25:16] Speaker 00:
You're honest.

[00:25:18] Speaker 03:
Mr. Bell, you have some rebuttal time on the cross appeal.

[00:25:23] Speaker 01:
Thank you, Your Honors.

[00:25:26] Speaker 01:
I still think the key issue for the cross-appeal and secondary considerations is that both the PTO and Mr. Greenspoon ignored that Claim 12 was found to be anticipated, and they argued that the claims and the Emmys and all of these awards were co-existed with an anticipated claim, and that should be case-responsible, unless Your Honors have anything further to add.

[00:25:49] Speaker 03:
Now, thank you all for your arguments.

[00:25:51] Speaker 03:
We will see you soon, in this case in submitted.