[00:00:00] Speaker 02:
first is number 22 1642 caravan canopy international.

[00:00:10] Speaker 01:
Good morning thank you your honors may please report.

[00:00:16] Speaker 01:
This case your honor in an appellant's

[00:00:21] Speaker 01:
A considered opinion is one where we really need to construe the claims of the patented issue in a way that preserves the validity of those claims.

[00:00:32] Speaker 01:
And the support for that is in the claims themselves.

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As this court knows, we're to first look to decipher the meaning of patent claims.

[00:00:45] Speaker 01:
And the board, in its construction, acknowledged

[00:00:50] Speaker 01:
that the claims that issue here, just three and really just claim one, the only independent claim of the 040 patent.

[00:00:58] Speaker 01:
And frankly, the opening clause of that claim, one, which is really the only part of the claim that we contend provides the board and this court with the claim language to support the validity, which the board

[00:01:18] Speaker 01:
would not concluded to the opposite, of course, which is why we're here on appeal.

[00:01:24] Speaker 01:
And so certainly my client, Haravan, the appellate didn't invent a tent.

[00:01:32] Speaker 01:
They didn't invent a tent with a collapsible frame.

[00:01:37] Speaker 01:
Tents have been around forever.

[00:01:39] Speaker 01:
But what they did invent and what the prior art does not show and what appellee has acknowledged

[00:01:47] Speaker 01:
The primary reference, the Yang reference doesn't show, is what's claimed in the first clause of claim one.

[00:01:55] Speaker 01:
A center pole in the tent constructed for stretching and sustaining.

[00:02:03] Speaker 01:
A tent's roof when a tent is pitched with tent frame.

[00:02:07] Speaker 02:
Why isn't Lynch, the primary reference Lynch, meet that particular limitation?

[00:02:14] Speaker 01:
Well, the board used Lynch as the secondary reference to complete the obviousness analysis.

[00:02:20] Speaker 02:
So you have one reference that meets, discloses an instant tent frame.

[00:02:25] Speaker 02:
Correct.

[00:02:27] Speaker 02:
And that, would you agree that that pretty much reads on your particular claim other than the center pole?

[00:02:35] Speaker 02:
And that's... That's the clause that I read.

[00:02:38] Speaker 02:
And that's disclosed by Lynch.

[00:02:40] Speaker 01:
Yes, but as this court knows, that doesn't end the inquiry in an obvious case.

[00:02:45] Speaker 01:
Now, both Yang and Lynch are prior tent frames.

[00:02:50] Speaker 01:
This is not complicated technology that we're talking about here.

[00:02:54] Speaker 01:
They're prior tent frames, neither of which shows the key element here, which is the stretching of the tent itself over the frame to add a structural significance.

[00:03:09] Speaker 01:
Now, anyone can go out and put a pole and lay a bed sheet over it.

[00:03:13] Speaker 01:
You've got a tent.

[00:03:15] Speaker 01:
But the only force acting there on the tent is gravity.

[00:03:19] Speaker 01:
And that's what's going on in both Yang and Lynch.

[00:03:22] Speaker 01:
There's no disclosure in those references of a center pole adding the dimension of the stretching and sustaining the tent frame, which, as you may imagine, if you go and try to knock over a tent that only is

[00:03:39] Speaker 01:
is held together by the force of gravity, there's going to be the tent itself will fall over or roll in the wind, but when you've got that tent strapped.

[00:03:50] Speaker 02:
You're not challenging the two prior references that were relied on.

[00:03:56] Speaker 02:
Your argument is one of motivation to combine, that there's no reason as to why Opposite would have combined both of those references.

[00:04:05] Speaker 01:
And I apologize, Your Honor, I should clarify exactly what my arguments are.

[00:04:08] Speaker 02:
That's your argument.

[00:04:09] Speaker 01:
Well, several arguments, any of which may result in a reversal.

[00:04:15] Speaker 01:
Claim construction, an issue this court reviews de novo.

[00:04:19] Speaker 01:
Here, we have the board say, this term at issue was to be read in the context of the invention by its plain and ordinary meaning.

[00:04:28] Speaker 01:
Now, there's evidence in the record of the board concluding what that plain and ordinary meaning was, which resulted in the obvious disruling.

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So first, we argue against the claim construction of the board.

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Second, we argue that the board did not treat Caravan's evidence fairly before the board by relying on the expert provided by the appellee and by discounting the evidence

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expert declaration provided by my client.

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Third, so an evidentiary issue that the board misapprehended the evidence, first claim instruction, second misapprehended the evidence.

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Third, the board should not have considered the evidence and argument that FLE put in before the board on reply because

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proceedings before the board on an IPR are supposed to be full and complete in the petition itself.

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Now, of course, there are exceptions where the reply argument is simply elaborating on the arguments presented in the petition.

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But here, we have an entirely new reply declaration from the expert of the petitioner before the board.

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We have the board relying

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specifically on the reply declaration of the expert of the petitioner in its final written decision.

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And we have deposition testimony admitting by the petitioner's expert that the motivation to combine, and let me find that.

[00:06:14] Speaker 01:
He admitted in his deposition that increased space for activities, a passage that was lifted from the Yang reference and cited in the petition, is related to underlying structure.

[00:06:26] Speaker 01:
And that's the key here, not canopy height, because it's achieved in Yang by removing a pillar going to the ground that occupies space in the main body of the tent.

[00:06:37] Speaker 01:
So that's a long-winded answer, Judge Ranat, to your question.

[00:06:41] Speaker 01:
But we challenge several aspects.

[00:06:42] Speaker 01:
First, claim destruction.

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Second, the board's ability to consider evidence and argument on reply.

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Third, I reordered them here.

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Third, the weighing and considering of the evidence in view of this court's advice to construe that.

[00:07:01] Speaker 02:
So, Councilor, we'll get down a little bit lower into the weeds here.

[00:07:06] Speaker 02:
Your argument is that stretching should be construed as tension or to make talk.

[00:07:14] Speaker 02:
The board construed the term stretching according to its plain and ordinary meaning as extending or spreading out.

[00:07:23] Speaker 02:
Extending or spreading out is referenced in the specification 11 times.

[00:07:28] Speaker 01:
Yes.

[00:07:28] Speaker 02:
That seems to me to be some pretty powerful evidence against your argument.

[00:07:37] Speaker 01:
Well, I don't write the patent, Judge Rainn.

[00:07:39] Speaker 01:
I have not.

[00:07:40] Speaker 01:
Joking.

[00:07:41] Speaker 01:
The patent is not written

[00:07:43] Speaker 01:
as perfectly as we would like.

[00:07:44] Speaker 01:
However, to go back to my argument of, in context of this invention, what is a tent?

[00:07:50] Speaker 01:
It's a material draped over a frame.

[00:07:52] Speaker 01:
So, gravity, right?

[00:07:56] Speaker 01:
Force of gravity will stretch whatever is laid over it because it's pulling down.

[00:08:01] Speaker 01:
However, stretching is also a particular kind of force.

[00:08:06] Speaker 01:
Because if you put a bed sheet over a tent frame, that's not stretching.

[00:08:10] Speaker 01:
That's just laying there.

[00:08:13] Speaker 01:
Obviously, there's a little force of gravity that's pulling those fibers apart very slightly.

[00:08:18] Speaker 01:
But that's not stretching.

[00:08:19] Speaker 01:
What we have here is stretching like a hamstring.

[00:08:24] Speaker 01:
Stretch your hamstring.

[00:08:25] Speaker 01:
The reason you're creating tension there because it's fixed on one end by your back of your knee.

[00:08:31] Speaker 01:
It's fixed on the other end higher up.

[00:08:34] Speaker 01:
And you've got stretch.

[00:08:37] Speaker 01:
Gravity's not stretching.

[00:08:39] Speaker 01:
but there is force of gravity operating on it.

[00:08:41] Speaker 01:
So what we contend on claim construction is that the board got it wrong by not construing the phrase constructed for stretching and sustaining a tense roof in a way that contrues this claim term in a way that preserves the validity.

[00:08:59] Speaker 02:
Here the board was just going-

[00:09:10] Speaker 01:
Well, I suppose my argument is that the board got it wrong under the law of claim instruction as guided by this court.

[00:09:21] Speaker 01:
And it's more of a policy argument, Your Honor, to say that we shouldn't have the Patent Office be granting patents and then have the Patent Office then so easily invalidate patents.

[00:09:35] Speaker 01:
So maybe let's not.

[00:09:39] Speaker 01:
do that, maybe let's not have the board so easily construe a claim term like this in a way that's not in appropriate context of the invention, in a way that so easily brings in... But that's the board's job.

[00:09:53] Speaker 02:
The board's job is to review PANs and to determine whether this should have been granted a PAN to begin with.

[00:10:00] Speaker 01:
That is the board's job.

[00:10:01] Speaker 01:
Yeah.

[00:10:01] Speaker 01:
Absolutely.

[00:10:02] Speaker 01:
But in doing that job, we should also recognize that claim terms should be construed correctly.

[00:10:09] Speaker 01:
And that's why we're here on appeal, because we don't believe it was done correctly.

[00:10:15] Speaker 01:
Now, the Lynch reference, the secondary reference, again, there's nothing in Lynch that discloses

[00:10:25] Speaker 01:
the missing element.

[00:10:26] Speaker 01:
And we all agree that the missing element in Yang is that first claim element of a center pole constructed for stretching and sustaining.

[00:10:35] Speaker 01:
So Lynch, just like Yang, discloses a drape over a tent frame.

[00:10:42] Speaker 01:
The only difference is the center pole is pushed up, and it's got more of a pitch in the roof of the tent.

[00:10:50] Speaker 01:
So there's really nothing different between Yang and Lynch other than Lynch

[00:10:55] Speaker 01:
suggests, according to the board, that we could modify gang to create more headroom inside the tent for a tall person standing in the middle.

[00:11:06] Speaker 01:
But that doesn't suggest or disclose, and certainly not giving a motivation to have that

[00:11:15] Speaker 01:
tent over the frame be stretched in a way that adds the structural heft or structural significance to it as we believe the claim should have been construed.

[00:11:26] Speaker 01:
So Lynch doesn't really add much.

[00:11:28] Speaker 01:
It certainly doesn't teach that tightened roof for structural purposes.

[00:11:36] Speaker 01:
Now, of course, some of our arguments obviously go together.

[00:11:40] Speaker 01:
If the claim construction is confirmed correctly, it doesn't allow some of our arguments to proceed.

[00:11:46] Speaker 01:
I admit that, Your Honor.

[00:11:49] Speaker 01:
So that claim construction argument is first.

[00:11:53] Speaker 01:
And you see from the context of the 040 patented issue that we've got side polls in the 10th

[00:12:06] Speaker 01:
They're spread out to the point where the frame and the ribs, the scissor-like ribs that provide that tension in the structure of the frame, and then you've got the tension in the tent material itself.

[00:12:21] Speaker 01:
But those ribs are fully extended, unable to move further, and kept in place by sliders on the frame.

[00:12:30] Speaker 01:
So again,

[00:12:32] Speaker 01:
This patent is not the first collapsible tank.

[00:12:35] Speaker 01:
So we have to look a little deeper, we suggest, to construe the claims correctly in the context of this invention.

[00:12:43] Speaker 01:
Now, the board said stretching in the scope of the 040 patent.

[00:12:53] Speaker 01:
So the board acknowledged.

[00:12:54] Speaker 01:
We've got to look a little bit of context.

[00:12:58] Speaker 01:
We've got to assess it.

[00:12:59] Speaker 02:
You're in here a long time.

[00:13:01] Speaker 02:
You want to save some?

[00:13:02] Speaker 01:
Pardon.

[00:13:03] Speaker 01:
You're into your bubble.

[00:13:04] Speaker 01:
Oh, I am sorry.

[00:13:07] Speaker 01:
I will say so.

[00:13:07] Speaker 01:
Thank you.

[00:13:12] Speaker 02:
Good morning, Your Honor.

[00:13:25] Speaker 00:
So this is a relatively simple issue on appeal here.

[00:13:31] Speaker 00:
It's really the primary issue is the motivation to have modified Yang to include the center pole disclosed in Lynch.

[00:13:41] Speaker 00:
Yang and Lynch both describe instinct canopies that have very similar structure to what's described in the 040 patent.

[00:13:48] Speaker 00:
They all have the side poles.

[00:13:50] Speaker 00:
They have the scissor ribs around the perimeter.

[00:13:53] Speaker 00:
And they have the center pole supports that go up to the apex.

[00:13:58] Speaker 00:
The only difference between Yang and the 040 patent is a disk at the apex.

[00:14:04] Speaker 00:
And Lynch was considered by the examining attorney during the prosecution of the 040 patent

[00:14:10] Speaker 00:
And the patentee distinguished Lynch only on the basis that those supports that go from the side poles up to the apex are telescoping.

[00:14:22] Speaker 00:
The patentee never said anything about Lynch not having a center pole.

[00:14:25] Speaker 00:
Lynch does have a center pole.

[00:14:27] Speaker 00:
The only difference was that those supports that go up to the center pole are telescoping instead of hinged as they are in the claims of the 040 patent.

[00:14:37] Speaker 00:
The patent owner talks a lot about

[00:14:40] Speaker 00:
the benefit of tensioning the roof, adding some structural heft or support.

[00:14:47] Speaker 00:
But that's not described in the 040 patent.

[00:14:49] Speaker 00:
There's nothing in the 040 patent that talks about providing a structural heft by tensioning the roof.

[00:14:58] Speaker 00:
There's simply no support for it.

[00:15:00] Speaker 00:
In the briefing below, the patent owner pointed to one figure

[00:15:07] Speaker 00:
in the 040 patent that shows some stippling that could be velcro that maybe would disclose attaching the roof to the side holes.

[00:15:19] Speaker 00:
But that's it.

[00:15:19] Speaker 00:
There's no discussion of it.

[00:15:20] Speaker 00:
There's no discussion about tensioning or strengthening the frame through tension.

[00:15:25] Speaker 00:
That's just not in the patent.

[00:15:27] Speaker 00:
So both the Lynch patent and the Yang patent describe the benefit of having increased headroom, which is what the 040 patent says it was trying to achieve, eliminating the structure underneath the roof to provide more space for people to stand, to have room for their head.

[00:15:54] Speaker 00:
And so one of skill in the art would have very clearly been motivated by, if nothing else, the disclosure in both the Yang patent and the Lynch patent to have taken these very similar structures and to have incorporated the center pole found in Lynch onto Yang to increase the headroom so that, particularly for somebody who's tall,

[00:16:17] Speaker 00:
Dr. Klopp, the petitioner's expert, explained, particularly for somebody tall, it would be a big benefit to have that extra space under the roof, even between the center pole ribs.

[00:16:33] Speaker 00:
And so that's a strong motivation to combine these references.

[00:16:39] Speaker 00:
The patent owners spent a lot of time just now discussing the claim construction and the board correctly construed the term stretching.

[00:16:53] Speaker 00:
That's really the term at issue here.

[00:16:55] Speaker 00:
The board construed that term in accordance with its ordinary meaning as spreading out.

[00:17:02] Speaker 00:
The patent owner would like to incorporate a requirement that there's tensioning of the roof by attaching it to the side poles, but there's nothing in the claim that even requires a roof.

[00:17:18] Speaker 00:
And certainly, there's nothing in the claim that has any structure, that recites any structure for attaching that roof to the sidewalls.

[00:17:25] Speaker 00:
Those simply are not limitations that are in the claim.

[00:17:28] Speaker 00:
And there's no basis to limit the meaning of the term stretching to incorporate these extra limitations into the claim.

[00:17:38] Speaker 00:
Judge Raina, as you recognize, the specification

[00:17:41] Speaker 00:
Discusses stretching in 11 different instances and in every single instance.

[00:17:47] Speaker 00:
It's used to mean spreading out There's nothing there's no place in the pattern not a single one where the term stretching is used to mean tensioning as like with a rubber band and

[00:17:58] Speaker 00:
And as Dr. Klopp recognized, that wouldn't even make sense.

[00:18:02] Speaker 00:
Somebody of skill in the art would recognize that the roof material used for these canopies generally is a canvas.

[00:18:10] Speaker 00:
Nobody uses a rubber band material in a roof covering for these canopies.

[00:18:18] Speaker 00:
So it really wouldn't make sense in the context of this invention to construe stretching

[00:18:25] Speaker 00:
as requiring tensioning rather than simply spread out as it's used in the specification of the patent.

[00:18:33] Speaker 00:
So the board's construction is well supported by the intrinsic evidence, both of the claim itself and the specification.

[00:18:46] Speaker 00:
It's also supported by Dr. Klopp, petitioner's expert.

[00:18:51] Speaker 00:
In his declaration, he explained that that is how one of skill in the art

[00:18:55] Speaker 00:
would understand the term.

[00:18:57] Speaker 00:
So the board properly construed the term.

[00:19:02] Speaker 00:
And so additionally, in the briefing, the patent owner never explained in his briefs why

[00:19:15] Speaker 00:
the construction that the patent owner argues for, this tensioning, would make a difference as to the outcome of this obviousness ruling.

[00:19:27] Speaker 00:
He explained a bit more now saying that Lynch doesn't disclose

[00:19:31] Speaker 00:
the center pole if it requires tensioning as he understands it to mean connecting the roof to the side poles to somehow provide some added support for the structure.

[00:19:46] Speaker 00:
But that's just not anything that's discussed as a benefit in the 040 patent.

[00:19:51] Speaker 00:
There's no disclosure in the 040 patent of any type of tensioning to increase the structural integrity.

[00:20:00] Speaker 00:
it's just not there.

[00:20:02] Speaker 00:
So there wouldn't be any basis to include that as a limitation.

[00:20:07] Speaker 00:
Additionally, the patent owner mentioned that one of the bases that the patent owner is relying on in this appeal was

[00:20:18] Speaker 00:
the board's decision to consider the petitioner's reply brief and the second declaration from Dr. Klopp.

[00:20:29] Speaker 00:
And that was entirely appropriate.

[00:20:34] Speaker 00:
The standard of review on that is abuse of discretion, and there's no basis to say that the board abused its discretion.

[00:20:41] Speaker 00:
in considering the reply.

[00:20:43] Speaker 00:
The petition specifically discussed the motivation to combine to modify Yang with Lynch to increase the headroom.

[00:20:54] Speaker 00:
And before the patent owner argued against it and made the argument about clear ceiling height, there was no way to anticipate the need to go into more detail about the benefits of being between the

[00:21:11] Speaker 00:
the support polls that go up to the apex and the added room even with those support polls.

[00:21:18] Speaker 00:
So in the reply, the petitioner and in Dr. Klopp's second declaration, he merely

[00:21:26] Speaker 00:
further explained that even though you still have those support poles from the side pole up to the apex, between those poles there is additional headroom.

[00:21:38] Speaker 00:
There was nothing in the petition that limited the motivation to needing higher clear ceiling height or room for

[00:21:49] Speaker 00:
I don't know, playing sports or moving around, or those types of activities.

[00:21:54] Speaker 00:
And the board recognized that there's no reason to even limit activities to things that require moving around as opposed to standing under the tent in order to stand with more headroom.

[00:22:08] Speaker 00:
So the motivation to combine

[00:22:13] Speaker 00:
Yang to include that centerfold of Lynch is well supported, both by, as I said, Lynch and Yang themselves, and by the testimony of Dr. Klopp, petitioner's expert.

[00:22:33] Speaker 00:
Additionally,

[00:22:35] Speaker 00:
In the briefing, the patent owner criticized the board for relying on Dr. Klopp's testimony, saying that it was conclusory.

[00:22:45] Speaker 00:
However, Dr. Klopp, both in his original declaration and in his second declaration, spent a number of paragraphs explaining why the prior art

[00:22:57] Speaker 00:
would motivate somebody that both the Yang and Lynch references, specifically one of those references, would motivate somebody to combine these two very similar structures to get that

[00:23:10] Speaker 00:
additional headroom and in the supplemental declaration which the board relied on Mr. Klopp provided a nice diagram showing that extra headspace and so it was a well-reasoned opinion it wasn't at all conclusory and the board was correct in relying on it and not excluding it.

[00:23:32] Speaker 02:
What's your response to the the argument that

[00:23:37] Speaker 02:
your friend on the other side makes that your expert testimony should not be considered because there was no documentation that accompanied the testimony itself.

[00:23:50] Speaker 00:
This goes to your comments regarding whether the

[00:23:59] Speaker 02:
the expert said so long it was conclusory.

[00:24:03] Speaker 00:
Right.

[00:24:03] Speaker 00:
The allegation that it was just the ipsa dixit of the expert.

[00:24:07] Speaker 00:
So we cited a case that it was perfect lab technology, acknowledging that it is appropriate for courts to rely on the common sense

[00:24:18] Speaker 00:
as someone skilled in the art, such as Dr. Klopp here.

[00:24:21] Speaker 00:
And in addition to his common sense explanation, he relies on the prior art itself, the statements in both Yang and Lynch, which extensively talk about the benefit.

[00:24:33] Speaker 00:
Lynch, for example, says that

[00:24:37] Speaker 00:
specifically says that the extended center pole provides the increased headroom, and Yang also describes the purpose of that invention as increasing space for activities for which the tent is used.

[00:24:50] Speaker 00:
And Dr. Klopp, in his declarations, went into analyzing the statements in those prior art patents and relied on those in addition to his common sense.

[00:25:04] Speaker 00:
to determine that there was a motivation to combine those references.

[00:25:12] Speaker 00:
So I think that there was no basis to exclude that testimony.

[00:25:17] Speaker 00:
The case that the patent owner relied on where an expert's testimony was excluded

[00:25:27] Speaker 00:
because it was conclusory was very strongly distinguishable from this one.

[00:25:32] Speaker 00:
It was nothing like this case.

[00:25:34] Speaker 00:
It involved improvements to electronic communications systems and the patent at issue in that case had a purpose of reducing power consumption and the two prior art patents.

[00:25:47] Speaker 00:
didn't say anything about reducing power consumption.

[00:25:49] Speaker 00:
They were for entirely different purposes.

[00:25:51] Speaker 00:
Here, by contrast, the two prior patents that were relying on for obviousness were trying to solve the same problem as the 040 patent.

[00:26:02] Speaker 00:
They specifically talk about increasing headroom, which is

[00:26:04] Speaker 00:
the purpose that the 040 patent is trying to solve.

[00:26:08] Speaker 00:
So this is a situation where the priority itself is very closely related.

[00:26:13] Speaker 00:
The structures that are disclosed are nearly the same as the structure in the 040 patent.

[00:26:19] Speaker 00:
There's very little difference.

[00:26:21] Speaker 00:
And they're all trying to solve exactly the same issue.

[00:26:36] Speaker 01:
Thank you, Your Honor, and thank you for pointing it out.

[00:26:40] Speaker 01:
I did reserve time, and I lost sight of that.

[00:26:42] Speaker 01:
A couple quick points.

[00:26:46] Speaker 01:
We're here.

[00:26:46] Speaker 01:
We shouldn't, based on obviousness grounds, especially where there's really a stretch, pardon the pun, to fit these prior references into what's claimed.

[00:26:57] Speaker 01:
I think we need to focus on that claim language of that first clause, constructed for stretching and sustaining a tense roof.

[00:27:06] Speaker 01:
Roof.

[00:27:07] Speaker 01:
Council stated, I believe I heard correctly, that nowhere in the patent is there a roof disclosed.

[00:27:13] Speaker 01:
It's right there.

[00:27:14] Speaker 01:
Roof.

[00:27:15] Speaker 01:
It's right in the claim.

[00:27:16] Speaker 01:
So I think we need to focus on that claim language.

[00:27:18] Speaker 01:
We need to focus on let's not casually invalidate patents on loose obviousness grounds.

[00:27:25] Speaker 01:
And I think that's what's done here.

[00:27:27] Speaker 01:
On the reply evidence, this is unusual.

[00:27:33] Speaker 01:
Even in district court, you file a motion, get your evidence in.

[00:27:37] Speaker 01:
Reply is not for new evidence.

[00:27:39] Speaker 01:
And if the argument was already in there, why do you need a reply declaration from the expert?

[00:27:44] Speaker 01:
And again, why was it not accompanied with any documentation?

[00:27:47] Speaker 01:
So there are several mistakes there, and the board relieved the burden of all of them.

[00:27:56] Speaker 01:
New reply declaration, no documents,

[00:27:59] Speaker 01:
It seemed to be fine.

[00:28:00] Speaker 01:
But in practice, it's not.

[00:28:04] Speaker 01:
And it should not have been relied on.

[00:28:07] Speaker 01:
And finally, regarding motivation to combine, there's just nothing in Lynch.

[00:28:19] Speaker 01:
or Yang that suggests that we need the Lynch reference to provide something that Yang is missing.

[00:28:30] Speaker 01:
Yang has adjustable side poles.

[00:28:34] Speaker 01:
If you need more room under the tent, just raise those poles up.

[00:28:38] Speaker 01:
So there was no reason to make that combination, and again, neither Yang nor Lynch.

[00:28:43] Speaker 01:
discloses anything akin to what's claimed.

[00:28:47] Speaker 01:
We need to keep our focus on that center pole constructed for stretching and sustaining.

[00:28:52] Speaker 01:
Just like gravity is very different force than tension, like when you stretch your hamstring.

[00:28:58] Speaker 02:
Thank you.