[00:00:01] Speaker ?: All right, our next case of argument is 22-2109, AI visualization versus nuanced communications. [00:00:11] Speaker ?: Is it Vinakota? [00:00:13] Speaker ?: Correct, Your Honor. [00:00:14] Speaker ?: Okay, go ahead. [00:00:15] Speaker 01: Thank you, Your Honors, and may it please the Court. [00:00:22] Speaker 01: Again, my name is Roger Kumar Vinakota, counsel for Appellant AI Visualize. [00:00:27] Speaker 01: The district court's decision to invalidate the patents in suit under section 101 is premised on a fundamental misunderstanding of the technology. [00:00:34] Speaker 01: The district court disregarded and replaced key limitations of the claim, leading to its incorrect and overgeneralized determination of what the asserted claims are directed to. [00:00:45] Speaker 01: When read correctly, without reading out and replacing invented features, the asserted claims are directed to patentable subject matter. [00:00:53] Speaker 01: I'll start first, for example, with representative claim one of the 619 patent. [00:00:57] Speaker 01: which provides an invention that's not directed simply to retrieving data or caching as a district court held. [00:01:05] Speaker 01: Rather, these claims are directed to novel systems for providing 3D virtual views from extremely large data sets, among other things by one, determining where frames that make up the 3D visualizations are stored locally, two, dynamically creating remaining frames required for the 3D visualization from the centrally stored large data set, [00:01:27] Speaker 01: And three, sequentially combining these stored and dynamically created frames to create the 3D visualization that user requested. [00:01:36] Speaker 02: I'd like to address a 3D visualization issue later until we're able to get to that. [00:01:42] Speaker 02: But it just seems to me that a lot of the claims are directed to the abstract idea of improving, manipulating, and displaying data. [00:01:53] Speaker 02: And our case law is pretty clear on that. [00:01:56] Speaker 02: This is an eligible subject matter. [00:02:00] Speaker 01: You're right, Your Honor. [00:02:01] Speaker 01: If the claims were directed to that abstract concept, your case law is clear. [00:02:06] Speaker 01: However, we do disagree that these claims are directed to that abstract. [00:02:10] Speaker 01: We believe these claims are directed to the very specific issue of creating the 3D visualization from that BVD data set. [00:02:19] Speaker 01: Particularly the reason why is from the specifications in column one and two, the 609 patent, it teaches that there are two main problems that were in the prior art. [00:02:28] Speaker 01: Number one, the bandwidth [00:02:30] Speaker 01: latency issues of transmitting a large set of data and also the processing information of the DVD set to create these 2D frames that eventually becomes a 3D virtual view. [00:02:42] Speaker 02: Doesn't the patent itself acknowledge it? [00:02:45] Speaker 02: Technology exists to get literally three-dimensional 3D views from the existing two-dimensional 2D views. [00:02:54] Speaker 01: It does, Your Honor. [00:02:56] Speaker 01: There's no dispute with that. [00:02:57] Speaker 01: In fact, it says that in column two also, right? [00:03:00] Speaker 01: What the issue was, the actual problem is, how do I transmit? [00:03:04] Speaker 02: If I have created... You're claiming that the 3D dimensional views is the claimed advance. [00:03:12] Speaker 01: No, Your Honor. [00:03:13] Speaker 01: What we are saying is how the 3D virtual view is created now. [00:03:18] Speaker 01: So in column two, with the Klaus article, where is it? [00:03:21] Speaker 01: So you're claiming the how. [00:03:23] Speaker 01: We're claiming... [00:03:25] Speaker 01: How, yes, Your Honor, the very specific how. [00:03:27] Speaker 02: When I look at the claim that how, it's retrieving information, displaying information, manipulating information. [00:03:35] Speaker 02: That's how it does it. [00:03:37] Speaker 02: The only problem with how it doesn't tell us how it's going to do that. [00:03:40] Speaker 02: All it does is tell us. [00:03:42] Speaker 01: Actually, Your Honor, it does. [00:03:43] Speaker 01: If you look at claim one on appendix 66, specifically the web application limitation, I think this is where the crux of this whole argument is going to be between both sides. [00:03:54] Speaker 01: In that limitation, there are multiple steps, which basically says a user will ask for a request for a 3D visualization. [00:04:02] Speaker 01: That request then will do one of two things, or actually does two, and you can actually look at figure three that's actually laid out the algorithm for that. [00:04:10] Speaker 01: It will look to look at the local cache or storage to see if there's existing frames. [00:04:15] Speaker 01: If not, it'll send the request over to the central location to create more frames. [00:04:22] Speaker 01: And this is where I want to pause for a second. [00:04:24] Speaker 01: New frames potentially have to be created now. [00:04:26] Speaker 01: They're not stored. [00:04:27] Speaker 01: They were never there in the central location. [00:04:30] Speaker 01: New frames are going to be created to fill in the gaps, essentially, for what the user requested. [00:04:36] Speaker 01: Those frames get transmitted back to the local [00:04:40] Speaker 01: in the case of a tablet or something like that. [00:04:43] Speaker 01: And those are then combined with the stored frames. [00:04:47] Speaker 01: So they're right there. [00:04:49] Speaker 01: That break is different from the case laws, what we cited with respect to just retrieving, transmitting, and combining again, because there was an actual creation step in the central server for frames that were missing in the stored, in the local area. [00:05:09] Speaker 01: And with that, what I just said is exactly, to answer your question, Your Honor, is how the virtual views are made, at least with respect to claim one of these patents. [00:05:21] Speaker 01: That's the how. [00:05:23] Speaker 01: Appellees had argued in their brief, there's no explanation of the how. [00:05:28] Speaker 01: Well, it's right there in the claims. [00:05:30] Speaker 01: Perhaps they were actually talking about the how to make the virtual view. [00:05:36] Speaker 04: I'm confused. [00:05:38] Speaker 04: You make it by creating frames? [00:05:42] Speaker 01: So I'm using their argument, your honor. [00:05:45] Speaker 04: I see this specification as describing the general idea of a user creating virtual views, but I don't see any details about how the server actually implements it. [00:05:56] Speaker 04: And that's my problem. [00:05:59] Speaker 04: The closest you get, I'll tell you, is column 9, line 34. [00:06:02] Speaker 04: That's the closest you get. [00:06:04] Speaker 04: But it's still just very general. [00:06:06] Speaker 04: You're saying, here's the how, but the how is really a function. [00:06:10] Speaker 04: It's not a how. [00:06:12] Speaker 04: You don't explain how this was actually going to occur. [00:06:17] Speaker 04: It's like me saying, care cancer by care cancer. [00:06:20] Speaker 04: That's not the how. [00:06:21] Speaker 01: I understand, Your Honor. [00:06:22] Speaker 01: Let me sort of back up a little bit. [00:06:24] Speaker 01: There's three kind of concepts I want to make sure that everyone understands. [00:06:29] Speaker 01: We have the DVD, which is the core data set. [00:06:33] Speaker 01: From the DVD, we create frames. [00:06:36] Speaker 01: And those frames creations first are outside the scope of, I think, even this argument. [00:06:42] Speaker 01: the how those are created, it's actually end of column eight, beginning of column nine, is how those actual frames are created from the BDD set. [00:06:50] Speaker 01: That's where the specifications teach it. [00:06:52] Speaker 01: But that how is actually more related to enablement, which is outside the scope here. [00:06:57] Speaker 01: Once those frames are created, and bottom column eight to the top of column nine explains that which is in the central server, then those get transmitted to the local device, [00:07:10] Speaker 01: And if there's actual frames that have already been stored locally, the patent claim itself then says you combine those, and that creates what's called a virtual view. [00:07:21] Speaker 02: We're really not looking at frames here. [00:07:22] Speaker 01: We're looking at virtual views for the positive. [00:07:25] Speaker 02: We're looking at virtual views, not frames. [00:07:28] Speaker 02: When you say frames, it may mean some sort of physicalness to this. [00:07:33] Speaker 02: And there is not. [00:07:34] Speaker 02: So we're looking at views. [00:07:37] Speaker 02: And we're not creating the views. [00:07:40] Speaker 02: You're bringing information together to a local station in order so that the user can utilize the views. [00:07:48] Speaker 01: But to answer your question there, the virtual views, if you look at the plain language right there, is a series of frames. [00:07:57] Speaker 02: The virtual views is a series of data, information. [00:08:03] Speaker 01: I agree. [00:08:05] Speaker 02: Basically what you're doing is you're moving this information around from one location to another. [00:08:11] Speaker 02: You're bringing it very close as closely as possible to the user so that the user can look at these views without any type of latency involved or any type of disruption. [00:08:23] Speaker 01: Respectfully, Your Honor, the issue here is when I combine these elements, these three steps, [00:08:30] Speaker 01: Again, what we have to also go back again under ALICE Step 1, so let me just go right back to ALICE Step 1 to answer your question, is the claim as a whole making any improvement to the existing technology at the time? [00:08:43] Speaker 01: What's the advancement over the art? [00:08:45] Speaker 02: Maybe the answer for you, and this is just I think in one part, this is a 609, [00:08:51] Speaker 02: It says that field of the invention of this invention, this invention in reading of appendix 58, column 1, line 15, this invention relates to a method and system for viewing [00:09:09] Speaker 02: At a client computer, a series of three-dimensional virtual views transmitted over the internet of a bottom visualization data set contained a one or more centralized database. [00:09:23] Speaker 02: I agree that to say that we're moving information around. [00:09:27] Speaker 02: And you know that our case law has said that that is not patent subject matter eligible. [00:09:33] Speaker 01: I agree. [00:09:34] Speaker 01: If you overgeneralize it to that level, the case law of this court does say that. [00:09:39] Speaker 05: But even when you were talking about what you thought was the specific how, it was, well, if the view is on the data level server, use it. [00:09:51] Speaker 05: If it's not, get it from the central server. [00:09:55] Speaker 05: I mean, that's just manipulating information. [00:09:58] Speaker 01: Again, using the... I want to... I'm not trying to correct anything, but it's frames. [00:10:03] Speaker 05: The views are... I don't care if it's frames or not. [00:10:07] Speaker 05: I mean, this isn't a patent on how to create those frames. [00:10:10] Speaker 05: It's a patent on how to use the computers to more efficiently get a 3D dimension, right? [00:10:18] Speaker 05: Using computers to more efficiently do an abstract idea is not patentable. [00:10:25] Speaker 01: Two points, one, we're still in the pleading stage and the specifications say that to just use a computer, the prior art couldn't do it. [00:10:36] Speaker 01: It was impractical and impossible. [00:10:38] Speaker 01: That's the language in column two. [00:10:39] Speaker 02: But you're not claiming a special computer here. [00:10:42] Speaker 01: No, what we're claiming is by using these three steps, [00:10:46] Speaker 01: we're finding an advancement over that limitation. [00:10:50] Speaker 02: Sir, what are those three steps? [00:10:52] Speaker 02: Okay. [00:10:52] Speaker 02: Collecting data, transferring data, and manipulating data. [00:10:57] Speaker 01: We had a step, we have to still create the data. [00:11:00] Speaker 01: That's the critical aspect, and I think that's the point of contention, which is at the time when a user asks for a view, and I cannot find stored local frames, I have to go back that central server [00:11:15] Speaker 01: agree to the VVD set there, but that VVD set now has to do processing and create additional frames to send it back. [00:11:25] Speaker 01: That point right there is what we're saying is not abstract. [00:11:29] Speaker 01: That is the point of where coming back and adding it with the rest of the claims has now created that advancement. [00:11:37] Speaker 05: Maybe this simplification is what you don't like, but the 3D view is on the central server. [00:11:46] Speaker 01: No, Your Honor. [00:11:47] Speaker 05: On the central server... The data is on the central server. [00:11:50] Speaker 01: It's 2D plan. [00:11:51] Speaker 01: It's a CT scan, essentially. [00:11:53] Speaker 05: All the data you need to put together, you are on the central server. [00:11:57] Speaker 01: The data is there, but you still... Actually, the patents take... So, I've got it. [00:12:01] Speaker 01: The data is there. [00:12:02] Speaker 05: You have data there. [00:12:03] Speaker 05: And some of the data may be downloaded onto the local server. [00:12:07] Speaker 01: That is not correct, because the data has to be found. [00:12:11] Speaker 05: What's on the local server? [00:12:13] Speaker 01: So on the local server, so on the local server is the data that is the frames. [00:12:19] Speaker 05: Okay. [00:12:20] Speaker 05: Some of the data is on the local server. [00:12:21] Speaker 01: Yes. [00:12:24] Speaker 01: The view is there too. [00:12:26] Speaker 05: And then if it's all there and it's all there, you don't need to do anything. [00:12:30] Speaker 05: But if it's not out there, you have to go back to the central server to get them to work to complete the view. [00:12:34] Speaker 01: Yeah. [00:12:34] Speaker 01: But the distinction is what are you getting more of? [00:12:37] Speaker 01: Okay. [00:12:37] Speaker 01: It's not, you're just not getting the CT scan and sending it over. [00:12:41] Speaker 01: Imagine me being a CT scan, and I want to become three-dimensional. [00:12:44] Speaker 01: I'm going to put a plane here, and then put my side over here, and all of a sudden, all my 3D organs come out. [00:12:49] Speaker 05: I mean, it sounds like a nifty software program to get really quick images, and maybe it should be patentable, but it doesn't sound to me like it's patentable under Alice and our precedent. [00:13:00] Speaker 01: Again, we tried to explain it all in our briefing, and Your Honors, my time is coming up for my rebuttal, but if there's more questions here. [00:13:08] Speaker 03: OK, we'll stay across here. [00:13:11] Speaker 00: I'm just going to jump right into the step one issue. [00:13:28] Speaker 00: the district court's decision and then addressing the argument that this is about creating the requested views. [00:13:35] Speaker 00: So first, AIV doesn't disagree as to what's the appropriate question for step one. [00:13:40] Speaker 00: It's what does the patent assert to be the focus of the claimed advance over the prior? [00:13:46] Speaker 00: There's no dispute there. [00:13:47] Speaker 00: And the court's characterization followed that standard. [00:13:50] Speaker 00: And it comes directly from the specification. [00:13:53] Speaker 00: Column 2, line 17 to 21, that's admitting how the prior art teaches that volume visualization from a server, you can paint it from a server without transmitting raw scans. [00:14:05] Speaker 00: So you can obtain the frames, the server can do all that work, and then you can transmit what you need to the client device. [00:14:11] Speaker 00: That's admitted as being known. [00:14:14] Speaker 00: Column two, lines 35 to 48, that's where they introduced the problem, overcoming bandwidth concerns by providing a common and centralized infrastructure for receiving, storing, processing, and viewing large medical scans. [00:14:27] Speaker 00: And then the key really is at columns 12, 31 to 49, and column 13, 10 to 38, where this issue of bandwidth usage is addressed by caching. [00:14:39] Speaker 00: The enhancement is the user makes a request, [00:14:42] Speaker 02: You check to see if the frames are stored locally, and if all the requested frames are not there, you go to the server to get them. [00:15:03] Speaker 02: and bandwidth. [00:15:05] Speaker 02: This pen matches those two problems. [00:15:10] Speaker 00: And that is addressed using this caching, which the court addressed and said, obviously, is a very well-known conventional technique, not patentable subject matter. [00:15:20] Speaker 02: The pen doesn't create a new apparatus of any kind. [00:15:26] Speaker 00: That's correct. [00:15:26] Speaker 02: All of the components... It does not require a specialized computer. [00:15:32] Speaker 00: all the components, no dispute, all the components to claim generalized components, no specialized components required. [00:15:38] Speaker 00: That's not in dispute. [00:15:39] Speaker 00: So let me talk about the issue that was raised by council, which is this is about creating the requested views. [00:15:46] Speaker 00: If you look at the claims, they recite nothing more than the generic step of quote, creating the requested frames of the requested views from the dataset in the central storage medium. [00:15:56] Speaker 00: Okay, so that's just a generic step. [00:15:58] Speaker 00: there is no how there of how the server is going to create the views and then if you if you look at the specification it confirms that creating the views that generic step is not the claimed advance over the prior art because the specification admits that that's already known in column one and column two of the patent [00:16:18] Speaker 00: it tells you that the background art involved these 3D virtual views that are created from 2D scans. [00:16:25] Speaker 00: So you have a 2D scan, set a database with 2D scans, and you can create 3D views from those 2D scans. [00:16:32] Speaker 00: But that's all known. [00:16:33] Speaker 00: And it's even known how to do that using a server-client interaction. [00:16:36] Speaker 00: Okay? [00:16:37] Speaker 00: So what the claims recite [00:16:40] Speaker 00: While they recite this step of creating the virtual views of the server, that's not what they are directed to when we ask what's the claimed advance over the prior. [00:16:49] Speaker 00: The claimed advance is transmitting only what you don't have stored locally. [00:16:54] Speaker 02: It's not the step of creating the virtual views. [00:17:06] Speaker 02: You get a 3D picture that's distorted, continuously distorted, and bandwidth. [00:17:12] Speaker 02: Ain't a lot of bandwidth and gave you a bad picture. [00:17:15] Speaker 02: And this invention is supposed to come along and give you a better picture by catching some of the data locally and only bringing in data as it's needed in order to get rid of the distortions. [00:17:29] Speaker 02: It deals with that basic problem, and therefore it deals with the, it requires more bandwidth. [00:17:36] Speaker 00: Right, but the problem is that the invention or the improvement is the abstract idea itself of caching. [00:17:44] Speaker 00: And there's the case law we cited in our brief from this court pretty clearly saying that caching is an abstract concept. [00:17:53] Speaker 00: And so even though caching does improve computers, you can't simply claim that as your improvement. [00:18:00] Speaker 00: I mean, abstract concepts can improve [00:18:03] Speaker 00: computers can make them more efficient, but you can't simply claim that. [00:18:06] Speaker 00: You have to claim more than that. [00:18:08] Speaker 00: And that's the issue here. [00:18:09] Speaker 00: And there's really no debate that what they are claiming is caching. [00:18:12] Speaker 00: It says it in their patent spec, and that's what they even accused of infringement in their complaint. [00:18:19] Speaker 00: I believe it was Appendix 146, where they actually say that this is what we're accusing. [00:18:26] Speaker 00: Step two? [00:18:27] Speaker 00: Yes. [00:18:28] Speaker 00: I think step two is actually quite simple. [00:18:31] Speaker 00: have accepted that for step one, what the claims are directed to, how Judge Andrews decided it. [00:18:36] Speaker 02: In step two, step two would decide whether there's anything that is actually going to save the patent. [00:18:42] Speaker 00: That's correct. [00:18:43] Speaker 00: And here, I think there's clearly nothing to save the patent, which is why you didn't hear much about step two. [00:18:47] Speaker 00: So for step two, for the group one claims, there was three groups of claims. [00:18:51] Speaker 00: For the group one claims, beyond the generic computer components and the generic functional steps of storing, retrieving, and transmitting data, the steps that [00:19:01] Speaker 00: focused on are the steps of checking if data is stored locally, and if not, obtaining the data from the server. [00:19:07] Speaker 00: And that is the well-known routine and conventional concept of caching. [00:19:11] Speaker 03: Do the Group 1 claims have a limitation that is directed to determining which frames should be stored locally? [00:19:19] Speaker 00: They simply say the step of determining whether [00:19:24] Speaker 00: this parameter stored locally. [00:19:26] Speaker 00: So that is the step. [00:19:28] Speaker 00: That's how caching works in any situation. [00:19:31] Speaker 00: You determine if you have it locally, and if not, you go retrieve it from somewhere else. [00:19:34] Speaker 00: So if you're web browsing, it's the same principle. [00:19:37] Speaker 04: No, that's not what I'm asking. [00:19:38] Speaker 04: Does the claim, does the group one claim have a determining step that decides which pieces of data to store locally, and which pieces of data not to store locally? [00:19:50] Speaker 00: I don't believe so how you frame that. [00:19:52] Speaker 00: I think what the claim says is determining if any frame of the request reviews is stored on the local storage medium. [00:19:59] Speaker 00: And then transmitting a request for any frame that is not stored. [00:20:04] Speaker 00: I don't believe as you're on a frame that that's what's claimed. [00:20:07] Speaker 02: That is the group two claims. [00:20:17] Speaker 00: And again, I think there, [00:20:19] Speaker 00: they're claiming simply the abstract idea of using an identifier, right? [00:20:25] Speaker 00: I mean, we have the secured mail case and the personal web case to talk about, you know, identifiers can make things more efficient, but you can't simply claim using a unique identifier to see if something's stored locally. [00:20:36] Speaker 00: That's claiming the abstract concept itself. [00:20:39] Speaker 00: There's nothing in the claims about how the unique identifiers is generated, [00:20:44] Speaker 00: what the nature of it is. [00:20:46] Speaker 00: So again, and I don't think you've heard any argument, you'll see in the argument from their side that the inventive concept here is the unique identifier. [00:20:53] Speaker 00: So that addresses the group two claims. [00:20:56] Speaker 00: And the last thing is the group three claims where you have this transmit low quality data first, then transmit high quality data. [00:21:04] Speaker 00: And this is simply the common sense principle that's discussed in the specification that low quality image data can be transmitted faster [00:21:13] Speaker 00: than high quality initiated. [00:21:14] Speaker 00: And that's exactly what Judge Andrew said, which is this is a common sense principle. [00:21:18] Speaker 00: It's not an inventive concept sufficient to transform the claims beyond an abstract idea. [00:21:23] Speaker 00: And I don't think there's actually any argument for plaintiff that that is an inventive concept. [00:21:29] Speaker 00: And I think also to the point of whether it addresses the bandwidth issues, it cannot because you have to transmit both the low quality data and the high quality data in the claim. [00:21:41] Speaker 00: It's not as though you're avoiding having the need for the bandwidth to transmit the high quality data. [00:21:47] Speaker 00: So I think that addresses the step two issues. [00:21:50] Speaker 00: And unless your honor has any questions, I'll see you in my time. [00:22:01] Speaker 01: Thank you, Mr. Desai. [00:22:01] Speaker 00: Thank you, Your Honors. [00:22:03] Speaker 01: I'd like to jump straight to what Judge Moreno was talking about with respect to step two. [00:22:08] Speaker 01: Counsel just said, essentially, the abstract concept is caching now. [00:22:12] Speaker 01: So if we're saying the abstract concept is caching, step two says, is there anything in the claimed features that make improvements to that? [00:22:20] Speaker 01: There are. [00:22:21] Speaker 01: If you actually look it back to the same steps again, we have to go to the local storage. [00:22:27] Speaker 01: That is caching. [00:22:27] Speaker 01: Because what is caching? [00:22:28] Speaker 01: Caching says, I give a request, the memory gives it back to me. [00:22:32] Speaker 01: But then I also have to go to the central server and create new data. [00:22:37] Speaker 01: That's not caching. [00:22:39] Speaker 01: But even if that's considered caching, there's a third step. [00:22:41] Speaker 01: I combine all those three back together again. [00:22:45] Speaker 01: That's not caching. [00:22:46] Speaker 01: But if all those concepts are caching, then that's a new form of caching, which then under step two means I've made an improvement over a generic concept. [00:22:55] Speaker 02: Now, one thing said here is, if you look at the... I don't think that's really what this invention is about. [00:23:02] Speaker 02: Our position is that's not what the invention is about. [00:23:05] Speaker 02: It's improvement and it's fixing the technology problem. [00:23:11] Speaker 01: Yeah, so what this improvement... I don't think that's what the invention is... I agree with you. [00:23:16] Speaker 01: That's not what the invention is. [00:23:17] Speaker 01: It's not about improving cash. [00:23:18] Speaker 02: How does that help you expect to do that? [00:23:21] Speaker 01: What it's saying is that cashing cannot be the abstract concept if that's their position. [00:23:32] Speaker 01: And I want to point you back to the district court's opinion on appendix 10 and 11. [00:23:38] Speaker 01: What the district court said is the abstract concept actually was to accomplish receiving user requested remotely stored information. [00:23:47] Speaker 01: Remotely stored. [00:23:49] Speaker 01: Then he goes to his [00:23:50] Speaker 01: step two analysis and says, okay, I have these same three steps that I've been talking about all day, which I have been. [00:23:57] Speaker 01: It's effectively caching. [00:23:59] Speaker 01: But the only limitation of those three that's talking about storage is the local, not even the central. [00:24:06] Speaker 01: So we think that was an error right there, that connection. [00:24:09] Speaker 01: But when you collapsed all those three into caching, [00:24:14] Speaker 01: then is that the actual abstract concept or is he saying that the inventive, there was no other inventive concept. [00:24:21] Speaker 01: So that to us with a disconnect, but counsel just said that the abstract concept was cashing. [00:24:27] Speaker 01: Okay, so if that's cashing, then those other three elements, which are not cashing, at least two out of the three are not cashing. [00:24:34] Speaker 01: Combined together, we still have those in the claims. [00:24:36] Speaker 01: So under step two analysis, I'm just saying that that cannot be the case. [00:24:40] Speaker 01: And that's why we go back to our position. [00:24:43] Speaker 01: What these patents are directed to, the abstract concept or the actual under step one, is to create 3D visualizations for a user request. [00:24:54] Speaker 01: And how did that patent accomplish that? [00:24:56] Speaker 01: By using these three steps that got around the prior problems of both bandwidth issues and processing issues. [00:25:03] Speaker 01: We've been talking about nothing but the bandwidth process, I'm sorry, bandwidth problems in the prior. [00:25:09] Speaker 01: But the actual specifications say there was a processing problem. [00:25:15] Speaker 04: Okay, counsel, we are over time. [00:25:16] Speaker 01: I want to thank your counsel for your argument. [00:25:17] Speaker 01: Thank you. [00:25:17] Speaker 01: Thank you, Your Honor.