[00:00:00] Speaker 01:
Your argument now in the second case of the morning, docket number 22-1230, Henry Universal Electronics, Incorporated.

[00:00:11] Speaker 01:
Mr. Lucas, is it?

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

[00:00:13] Speaker 01:
OK.

[00:00:14] Speaker 01:
And you reserve three minutes of rebuttal?

[00:00:15] Speaker 01:
That's correct, Your Honor.

[00:00:17] Speaker 01:
Please begin whenever you're ready.

[00:00:19] Speaker 01:
Thank you.

[00:00:23] Speaker 00:
May it please the court?

[00:00:26] Speaker 00:
Appellant, Universal Electronics, respects the requests

[00:00:30] Speaker 00:
reversal of the finding of the board rejecting claims 1 through 12 of the 451 application, unpatentable as obvious.

[00:00:40] Speaker 00:
I'm going to raise two arguments, get into two major arguments that require this court's reversal.

[00:00:47] Speaker 00:
One is that the board's decision did not find that Garg, the primary reference, discloses the claimed switching device.

[00:00:59] Speaker 00:
And the second argument is going to be that the board's motivation to combine Guard and IGO is not legally sufficient.

[00:01:10] Speaker 01:
Can I try to understand what this claim convention is?

[00:01:16] Speaker 01:
The remote control sends a command signal, and then that command signal is read by two different devices.

[00:01:25] Speaker 01:
One is the switching device, and one is the source device, i.e.

[00:01:29] Speaker 01:
the DVD player.

[00:01:30] Speaker 01:
So the remote control sends this IR command signal, and it's really meant for the DVD player.

[00:01:40] Speaker 01:
But at the same time, the switching device

[00:01:43] Speaker 01:
recognizes this IR command signal as well and understands that it needs to connect the DVD player to the television set.

[00:01:53] Speaker 01:
So in that sense, we're talking about a command signal that's doing double duty in that two different devices are responding to the same signal.

[00:02:03] Speaker 00:
I wouldn't say double duty, but most of that is correct.

[00:02:06] Speaker 00:
Basically, you have this switching device.

[00:02:08] Speaker 00:
I would call it an automatic switching device.

[00:02:10] Speaker 00:
It's kind of like your hub in an entertainment system.

[00:02:14] Speaker 00:
And so you have, like you said, TVs, stereos, DVD players, all connected to that.

[00:02:21] Speaker 00:
And what it does is this automatic switching device has special logic that's able to recognize remote controls from all the different appliances that you have connected to that system.

[00:02:36] Speaker 00:
And then once it receives it, it automatically determines what appliance for appliances it needs to

[00:02:45] Speaker 00:
activate and then control from from the specific remote because if you remember uh... what is what you just said different from what i had said well i i i think it was that that that uh... you said something i was confused a little bit about the dual that there's actually the remote said something twice i don't think that now the remote sends one signal one signal but that one signal actually uh... being acted on by two different devices

[00:03:13] Speaker 01:
The DVD player understands, aha, the remote control is telling me to do something.

[00:03:19] Speaker 01:
And so the DVD player is going to react to that.

[00:03:22] Speaker 01:
Secondly, there's this thing called the switching device, the hub, where the hub is seeing that same signal that's really designed to be sent

[00:03:33] Speaker 01:
and recognized by the DVD player, and is seeing that that signal is telling the DVD player to do something.

[00:03:41] Speaker 01:
And so the hub now needs to connect the DVD player to the television set.

[00:03:46] Speaker 00:
That's correct.

[00:03:47] Speaker 00:
But in certain systems, I would say that if you, let's use what we know, in the old prior art,

[00:03:56] Speaker 00:
You would have to press specific buttons, input buttons, to say, oh, I want to use the DVD player.

[00:04:04] Speaker 00:
So let the entertainment system, or those called a hub, turn over to the DVD player, and then we can use it.

[00:04:13] Speaker 00:
What we're doing here is it's all automatically done.

[00:04:16] Speaker 01:
So it is in my example, too.

[00:04:22] Speaker 01:
One signal.

[00:04:23] Speaker 00:
Correct.

[00:04:24] Speaker 01:
The hub catches the signal.

[00:04:26] Speaker 01:
The DVD player catches that same signal.

[00:04:28] Speaker 01:
It's meant for the DVD player.

[00:04:30] Speaker 01:
But at the same time, the hub also recognizes that because it's a signal meant for the DVD player, the hub needs to connect the DVD player to the television set.

[00:04:41] Speaker 00:
In your example, though, if you don't have the automatic switching and you don't have this switching device that is able to interpret all the different signals of the different devices, it was like an old hub.

[00:04:52] Speaker 00:
it might not activate the dvd plan to stand up at the end of the does the link for one point out okay okay two different devices recognizing the same signal and acting on it i think that's i think that's correct yes you if you go to the switch you go to the switching device it recognizes and then a lot automatically says i've got a make sure the dvd player uh... is is acted on is controlled uh... so

[00:05:22] Speaker 00:
Does that answer your question?

[00:05:24] Speaker 00:
I was going to get into that, but it looks like you took it to the window.

[00:05:29] Speaker 00:
No, it was good.

[00:05:31] Speaker 00:
I think when you get into the first argument that the primary reference doesn't disclose this automatic switching device, the claim switching device, and in particular the detection or determining limitation, and then the responding to limitation, I think that background really does illustrate that.

[00:05:52] Speaker 00:
The board's, and let me just go right to that, what I'm talking about, the limitation.

[00:05:58] Speaker 00:
Claim five of our brief determined that the receiver or the switching device has received an infrared IR signal transmitted by a remote control device.

[00:06:07] Speaker 00:
Where in?

[00:06:09] Speaker 00:
The IR signal transmitted by the remote control device comprises a protocol and a command value that is directly recognizable by a first device among the plurality of source devices and the sync device.

[00:06:20] Speaker 00:
So this is saying, look, this switching device has to be able to recognize that.

[00:06:25] Speaker 00:
It has to be able to automatically switch to that.

[00:06:27] Speaker 00:
It has to have all this logic.

[00:06:29] Speaker 00:
It has to know all the different remotes and their commands.

[00:06:33] Speaker 00:
And that's extremely important because the board said,

[00:06:39] Speaker 00:
that Garg disclosed that limitation in the board's decision.

[00:06:47] Speaker 00:
I can take you to that.

[00:06:49] Speaker 00:
At appendix 8 and 9, the board says, look, Garg teaches a switching device, the determining limitation, the in-response limitation.

[00:07:03] Speaker 00:
That's at 9.

[00:07:04] Speaker 00:
And then later on, at appendix 11, makes very clear,

[00:07:09] Speaker 00:
midway down as discussed above, the examiner cites Gorg for teaching the determining limitation and the detecting limitation.

[00:07:17] Speaker 00:
So using that as a frame of reference, then you go back and you say, well, the examiner's already said in his final office action that the board was addressing that Gorg doesn't disclose this switching device that does the determining and the responding.

[00:07:38] Speaker 00:
It doesn't.

[00:07:39] Speaker 00:
And that's here.

[00:07:41] Speaker 00:
If you look at Appendix 229, about midway down, Garg fails to disclose wherein the IR signal transmitted by the remote control device comprises a protocol and a command value that is directly recognizable by a first device among the plurality of source devices and the safe device.

[00:08:03] Speaker 00:
And what's important about that, it's interesting, if you look back at Appendix 228,

[00:08:08] Speaker 00:
What the examiner did there is he looked at the claim in order, and then you can see on 228 the method.

[00:08:19] Speaker 00:
We were talking about claim five, but this is the method of the switching device detecting or determining.

[00:08:25] Speaker 00:
And then he goes through the whole claim.

[00:08:27] Speaker 00:
And then later on at the end, in isolation, he says, oh, guard doesn't do this, part of the determining limitation.

[00:08:34] Speaker 00:
But let's just throw in Igo.

[00:08:36] Speaker 00:
But then when he goes to Igo, and I won't even want to get there, he doesn't say Igo's doing that.

[00:08:41] Speaker 00:
And there's no dispute before this court that Gord, the primary reference, doesn't disclose the automatic switching device that determines a response.

[00:08:55] Speaker 00:
The director has already

[00:08:57] Speaker 01:
I guess the question is, we already know, it was known in the art for remote control to send a signal to the hub to do the connection between different devices.

[00:09:08] Speaker 01:
It's also known they are to send command signals directly to a particular device, like a DVD player.

[00:09:16] Speaker 01:
So why wouldn't it be obvious to combine those two signals into the same signal so that you can have both functionalities occur at the same time since we already got a remote control sending a signal?

[00:09:29] Speaker 00:
I would say it's not obvious because on the record,

[00:09:32] Speaker 00:
The board has not said any of that, first of all.

[00:09:37] Speaker 00:
That's my first response.

[00:09:38] Speaker 00:
And they've actually gone and they said, Garg teaches this.

[00:09:42] Speaker 00:
And we know Garg doesn't teach it.

[00:09:43] Speaker 00:
The examiner has said it, and now the director has said it.

[00:09:46] Speaker 00:
So it's not a suggestion or a motivation to combine issue.

[00:09:50] Speaker 00:
We have to look at the board's decision, and the board has said, or this court has to look at the board's decision.

[00:09:54] Speaker 00:
The board says, Garg, the primary reference, teaches this limitation, teaches this claim switching device that determines

[00:10:01] Speaker 00:
and responds.

[00:10:03] Speaker 00:
And it doesn't.

[00:10:03] Speaker 00:
The examiner has said it doesn't.

[00:10:05] Speaker 00:
And then the director agrees.

[00:10:08] Speaker 01:
I thought the director was supporting the board decision.

[00:10:14] Speaker 00:
Well, I mean, I think it's supposed to.

[00:10:18] Speaker 00:
But the board decision wasn't the most favorable for the director to respond to.

[00:10:22] Speaker 00:
But if you look at the director's brief at nine, I mean, Garg discloses a switching device, but fails to specifically teach

[00:10:29] Speaker 00:
that the switching device acts in response to an IR signal sent by a remote control device wherein the IR signal comprises.

[00:10:36] Speaker 00:
And we've discussed that.

[00:10:38] Speaker 00:
They go on.

[00:10:40] Speaker 00:
So we have the examiner.

[00:10:42] Speaker 00:
We have the board's decision.

[00:10:43] Speaker 00:
And now we have the director saying, look, GARG, the primary reference, doesn't disclose this.

[00:10:48] Speaker 00:
And it requires reversal.

[00:10:50] Speaker 00:
There's no evidence in the record that GARG, the primary reference used by the board, discloses this limitation.

[00:10:56] Speaker 01:
But I thought the rejection is based on a combination of references.

[00:11:01] Speaker 00:
It is.

[00:11:03] Speaker 00:
It is.

[00:11:03] Speaker 01:
Combining IGO with GARG.

[00:11:05] Speaker 00:
Right.

[00:11:07] Speaker 00:
But the board relies on GARG for that limitation.

[00:11:10] Speaker 00:
And if you want to talk about IGO, I can talk about IGO.

[00:11:15] Speaker 00:
All IGO does, and all the board says it does, or the examiner, is it allows you to control a device with a remote.

[00:11:24] Speaker 00:
That's it.

[00:11:24] Speaker 00:
It doesn't have the automatic switching device either.

[00:11:28] Speaker 00:
It doesn't have the claim switching device.

[00:11:30] Speaker 00:
So you don't have it in the combination.

[00:11:31] Speaker 00:
That's why, if you look at the board's brief, the board says, OK, the director says the board's decision is not very good.

[00:11:40] Speaker 00:
Why don't we now modify GARC, something I think you brought up.

[00:11:43] Speaker 00:
The problem is that's not in the record.

[00:11:45] Speaker 00:
There's nothing there.

[00:11:46] Speaker 00:
GARC doesn't disclose it.

[00:11:47] Speaker 00:
IGO doesn't disclose it.

[00:11:49] Speaker 00:
And now, left with this

[00:11:51] Speaker 00:
a bad board decision, the director saying, well, yeah, but maybe we should just modify GARG to allow it to have this switching device that does the automatic switching.

[00:12:03] Speaker 00:
The problem is that's not in the record, and there's no support for that in the record.

[00:12:07] Speaker 00:
The examiner of the board has never discussed modifying GARG in view of anything.

[00:12:14] Speaker 00:
The only discussion about modification is- And hypothetically, everything that's in the director's

[00:12:20] Speaker 01:
was in the board's decision.

[00:12:22] Speaker 01:
I recognize that's not true, right?

[00:12:26] Speaker 01:
The director's brief uses different words.

[00:12:28] Speaker 01:
Let's assume for the moment that that's the basis of the board's decision.

[00:12:35] Speaker 01:
See the director's brief.

[00:12:37] Speaker 01:
What would your response be to the nature of that rejection?

[00:12:42] Speaker 00:
I think it's a better shot at showing obviousness.

[00:12:47] Speaker 00:
We still don't have any references that actually teach or even suggest this switching device, this automatic switching device.

[00:12:57] Speaker 00:
We don't have that.

[00:12:59] Speaker 00:
We have the Garg device.

[00:13:00] Speaker 00:
All it does is just response to a single remote for itself.

[00:13:04] Speaker 00:
That's it.

[00:13:05] Speaker 00:
That's all Garg does.

[00:13:06] Speaker 00:
And then all you have in IGO is a remote that just allows you to control specific

[00:13:14] Speaker 00:
Devices, that's it.

[00:13:15] Speaker 00:
So there's no there's no suggestion there that you have this autumn for this automatic switching device in either reference There's it's nice.

[00:13:23] Speaker 00:
It's not in the record.

[00:13:24] Speaker 00:
It's not in those two pieces of prior art So I would say it also it should also fail That would be my response So so that

[00:13:35] Speaker 00:
that addresses the first argument.

[00:13:37] Speaker 00:
And the second argument relates to the motivation combined.

[00:13:42] Speaker 00:
So the board just

[00:13:56] Speaker 00:
just kind of a, it actually doesn't even talk about the feature.

[00:13:59] Speaker 00:
If you look at, about what was modified or what was combined, if you look at appendix 11, which is the board decision, it says, in particular, the examiner finds one skilled in the art would have modified Garg system to incorporate IGO's feature in order to facilitate communications with the remote controller.

[00:14:16] Speaker 00:
Well, clearly,

[00:14:17] Speaker 00:
That, I don't know what the feature is.

[00:14:19] Speaker 00:
I think the board was a little concerned about the examiner's prior decision and just kind of said feature.

[00:14:25] Speaker 00:
I'll just throw that in there.

[00:14:27] Speaker 00:
It also shows that the office section was a little, I guess, tenuous.

[00:14:34] Speaker 00:
But that only relates to remote controls.

[00:14:36] Speaker 00:
That has nothing to do with switching devices.

[00:14:41] Speaker 00:
And all the board is saying and all the examiner said was,

[00:14:45] Speaker 00:
you would have added a remote control that could control devices because you would want the remote control to control devices.

[00:14:53] Speaker 00:
That's also not a legally sufficient motivation to combine.

[00:14:56] Speaker 00:
And so we ask that the court also reverse this decision for that reason.

[00:15:06] Speaker 00:
I think you have two solid reasons for reversal here, because the record is just

[00:15:13] Speaker 01:
I guess your point is, even if there was a motivation to combine these two references, the combination that the board and examiner has conceived of doesn't actually match up with the claimed invention.

[00:15:25] Speaker 01:
Correct.

[00:15:26] Speaker 01:
OK.

[00:15:26] Speaker 01:
Let's hear from the other side.

[00:15:28] Speaker 01:
OK.

[00:15:28] Speaker 01:
Thank you.

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

[00:15:31] Speaker 03:
May it please the court?

[00:15:33] Speaker 03:
I guess I'd like to start out by acknowledging that the board decision here is not the perfect example of PTO work products.

[00:15:41] Speaker 03:
Agreed.

[00:15:43] Speaker 03:
The red brief says a lot of interesting new things.

[00:15:49] Speaker 03:
I think that because of the straightforward nature of this case, you can still get to a point to be comfortable.

[00:15:58] Speaker 01:
Is this where you're going to tell me it wouldn't be productive to send it back to the PTO because these claims, even though the board may have botched it, are super obvious?

[00:16:08] Speaker 03:
No, I would say that we have a case where we have a claimed invention with just the concept of sending one IR signal to do two things.

[00:16:24] Speaker 03:
And that's disclosed in all of a paragraph and specification.

[00:16:29] Speaker 03:
It doesn't tell you how to do that.

[00:16:31] Speaker 03:
It just says... Where's it disclosed in the references?

[00:16:35] Speaker 03:
Well, the references guard

[00:16:38] Speaker 03:
includes a schematic drawing of all the internal electronics and talks about... I guess the answer is that no one reference actually discloses that limitation.

[00:16:50] Speaker 01:
You have to kind of piece these two references together, free your mind a little bit, and then you can find that limitation.

[00:16:57] Speaker 01:
Is that fair to say?

[00:16:59] Speaker 03:
Yes, but I think that I would say that

[00:17:04] Speaker 03:
There's been a lot of focus on the fact that guard doesn't disclose this automatic switching, but if guard disclosed the automatic switching, we would have an anticipation case because guard would do everything.

[00:17:16] Speaker 02:
Sure, but if guard doesn't disclose automatic switching, then something needs to disclose automatic shifting.

[00:17:23] Speaker 03:
I go is is very close and I think that When did it very close get to be good enough?

[00:17:29] Speaker 02:
Well, let let me explain I go shows where I go.

[00:17:33] Speaker 02:
Does it disclose the automatic?

[00:17:37] Speaker 03:
Paragraph I believe let me just get it up.

[00:17:41] Speaker 03:
So I have it right it's Paragraph 42 of I go this is appendix page 451

[00:17:53] Speaker 03:
discusses that the hub will switch when it recognizes a user interacting with the device.

[00:18:03] Speaker 03:
So it gives the example of a user putting a DVD into a DVD player.

[00:18:07] Speaker 03:
It says that once the user puts the DVD into the DVD player,

[00:18:10] Speaker 03:
the hub will recognize that and automatically switch to the DVD player.

[00:18:15] Speaker 03:
So there is automatic switching, it's just... It's not through the remote.

[00:18:19] Speaker 03:
No, instead of pushing a button on a remote, you're maybe pushing a button on the face of a source device.

[00:18:26] Speaker 03:
Does the board rely on this particular passage or if I go?

[00:18:29] Speaker 01:
No.

[00:18:29] Speaker 01:
Okay, I remember reading it somewhere, but that was in your red group.

[00:18:33] Speaker 01:
Yes.

[00:18:33] Speaker 02:
Okay.

[00:18:34] Speaker 02:
Shouldn't we at least have, at the minimum, have an explanation from somebody

[00:18:39] Speaker 02:
before you that this equivalent switching basically teaches the same thing as the remote switching?

[00:18:47] Speaker 02:
If it actually disclosed a remote switching, then maybe you've got substantial evidence.

[00:18:55] Speaker 02:
step away from that and I can see how you might get there.

[00:18:58] Speaker 02:
A skilled artist might look at this and say, there's no functional difference between using a remote to switch or actually doing a physical act like putting in a DVD or something else.

[00:19:10] Speaker 02:
I think your opponent would disagree, but at least we would have that explanation.

[00:19:15] Speaker 03:
Correct.

[00:19:16] Speaker 03:
And if this explanation is not sufficient, I understand if the case can be remanded for a clear explanation.

[00:19:26] Speaker 01:
Is it your view that the Appellant's counsel before the board was mischaracterizing the examiner's findings and wrote an unclear brief that was conclusory?

[00:19:38] Speaker 01:
Because that's what the board said about

[00:19:41] Speaker 01:
the board brief by the applicant?

[00:19:43] Speaker 03:
Yeah, I think that the... Do you mean those statements by the board?

[00:19:47] Speaker 03:
I wouldn't go as far as what the board said about the quality of their brief.

[00:19:52] Speaker 03:
I think that it was a bit confusing because they were just kind of making these statements saying, Garve doesn't disclose this, IGO doesn't disclose this, without some follow-up explanation.

[00:20:04] Speaker 01:
It's true that neither of those references disclosed this particular limitation.

[00:20:09] Speaker 01:
of a single IR command signal being responded to by two different devices.

[00:20:15] Speaker 03:
And if they had explained why, I think that would have helped the board.

[00:20:19] Speaker 02:
Maybe if the examiner explained why it was shown, it would have helped the board too.

[00:20:27] Speaker 03:
That's true.

[00:20:28] Speaker 01:
I think the examiner... If we remand this, the examiner's not just going to shoot a patent out the door, right?

[00:20:37] Speaker 03:
I mean, that decision is not necessarily in my hands, but I would strongly recommend that this application go back for further examination.

[00:20:47] Speaker 03:
Because I think that there are, beyond these two references, I think you can make an obviousness rejection based on what's admitted in the specification.

[00:20:57] Speaker 03:
I think you can make a 112 rejection based on the fact that this is all disclosed in a single paragraph that doesn't tell you how to do any of this.

[00:21:07] Speaker 03:
If this came back, it would be my hope that we would provide a better rejection on the next go-around.

[00:21:15] Speaker 03:
But I can't make this rejection say any more than it does.

[00:21:23] Speaker 03:
And I think that the examiner's answer, at least, acknowledges that you would have to modify Garg's switching device.

[00:21:30] Speaker 03:
This is on appendix page 315.

[00:21:37] Speaker 03:
I think both the examiner and the board, while being incredibly brief, recognize that one reference guard shows a remote control sending a signal that controls the switching device.

[00:21:53] Speaker 03:
The other reference, IGO, has a remote control that directly controls the source device.

[00:21:59] Speaker 03:
And putting these two together can get you

[00:22:04] Speaker 03:
you know, one signal that does both.

[00:22:06] Speaker 03:
You know, there's not really much more said beyond that.

[00:22:11] Speaker 03:
But I think that, again, the straightforward nature of this, that the idea that you'd want to simplify the process.

[00:22:18] Speaker 03:
I mean, you know, you've encountered the situation where you go into your living room and you have all these remotes sitting there and you have to try to figure out, you know, what turns on what and how do I control this.

[00:22:31] Speaker 03:
The idea of going from, well, one remote that you press a button to change the input and then press another button to control the source device to just pressing one button.

[00:22:40] Speaker 03:
I mean, we're going from pressing two buttons to pressing one button.

[00:22:44] Speaker 03:
And it just doesn't seem like that difference is enough.

[00:22:50] Speaker 03:
That step gets you a patent.

[00:22:54] Speaker 03:
But that's what I think.

[00:23:00] Speaker 03:
the examiner and the board were getting at, but it's not explained as clearly as that, unfortunately.

[00:23:12] Speaker 03:
No further questions?

[00:23:14] Speaker 01:
Thank you.

[00:23:15] Speaker 01:
I just had a couple of comments.

[00:23:26] Speaker 00:
I think the important point is that

[00:23:30] Speaker 00:
The prior art doesn't disclose the claim switching device with this special automatic switching logic.

[00:23:38] Speaker 00:
There was a reference to IGO at Paragraph 42 that's not automatic through the remote, that wasn't relied on by the board.

[00:23:47] Speaker 01:
It is automatic, is it not?

[00:23:51] Speaker 01:
If you press the button on the DVD player, the iGO's hub automatically connects the DVD player to the sync device.

[00:24:02] Speaker 00:
I guess in the sense that, yes, without a remote, just with the pressing of the button.

[00:24:07] Speaker 02:
Right, but if the examiner or the board, if the examiner had said, well, iGO only teaches it through inserting a DVD, but we see no different, and a skilled artisan would know that doing it through a remote is the same thing.

[00:24:21] Speaker 02:
then that conclusion would be up here for substantial evidence review.

[00:24:28] Speaker 00:
I still think you're just pressing the button is not the same as being able to recognize all the different remote control signals in an automatic switching hub or automatic switching device.

[00:24:41] Speaker 00:
But I think you're saying, I think your question is if they would have

[00:24:45] Speaker 00:
developed the motivation to combine better, yes, I think it would be a better argument, I guess, is my response.

[00:24:54] Speaker 02:
I mean, the argument is, IGO teaches automatic swishing.

[00:24:56] Speaker 02:
It just does it.

[00:24:58] Speaker 02:
through the devices themselves rather than the devices remotes, but there's no difference from there.

[00:25:04] Speaker 02:
And you can argue about that.

[00:25:06] Speaker 02:
I mean, it's kind of pointless for us to argue about something the examiner didn't find, but I think he'd have a much harder case if the examiner made that

[00:25:16] Speaker 02:
that finding.

[00:25:17] Speaker 00:
I would agree with that.

[00:25:18] Speaker 00:
I mean, the automatic versus manual, I think kind of when you push a button, that's a manual push, but I agree with you, I guess, that once you push the button, something happens.

[00:25:28] Speaker 02:
You're pushing a button on a remote, too.

[00:25:29] Speaker 00:
True, true.

[00:25:32] Speaker 00:
But I think the point, I didn't want to... Let me just... No, never mind.

[00:25:38] Speaker 02:
We'll do it another time.

[00:25:39] Speaker 02:
You're over your time.

[00:25:40] Speaker 00:
I just want to say, I probably would request a reversal.

[00:25:43] Speaker 00:
I don't think the board should get another shot at this.

[00:25:46] Speaker 00:
I think this is definitely a case where this court should just reverse based on the record evidence.

[00:25:55] Speaker 00:
Thank you, Your Honor.

[00:25:55] Speaker 01:
Thank you very much.

[00:25:56] Speaker 01:
Thank you, Your Honor.