[00:00:00] Speaker 03:
OK, the next case is 22-1342, Ultravision Technologies versus Flux Visual.

[00:00:10] Speaker 03:
And Mr. Martin remains where he is.

[00:00:12] Speaker 03:
And Mr. Lambrian, no coast.

[00:00:16] Speaker 03:
Is that right at all?

[00:00:19] Speaker 03:
Please proceed.

[00:00:21] Speaker 01:
Good morning, Your Honors, and may it please the Court.

[00:00:24] Speaker 01:
There are two independent reasons

[00:00:26] Speaker 01:
why the board's decisions in validating the 869 and 294 challenge claims should be reversed.

[00:00:33] Speaker 01:
The first is that there is no substantial evidence supporting the board's finding that the LED display panels disclosing Guoshi are configured to be used without a cabinet.

[00:00:45] Speaker 01:
Second reason is that Guoshi does not disclose, either explicitly or inherently, a plastic housing in its inventive embodiment, which is required for anticipation

[00:00:56] Speaker 01:
in the 1050 IPR.

[00:00:58] Speaker 01:
For the 1049 IPR, a secondary reference, Kim, teaches away from combining its teachings with a plastic housing.

[00:01:08] Speaker 01:
Regarding the first issue, petitioners relied on Gwoshi for the disclosure of a modular display panel in his petition.

[00:01:17] Speaker 01:
A modular display panel was construed as a panel which is configured for use without a cabinet.

[00:01:24] Speaker 01:
But Guoshi discloses LED modules that use a cabinet.

[00:01:28] Speaker 02:
Does your argument boil down to case element two being a cabinet, in your view?

[00:01:35] Speaker 02:
And there was no substantial evidence to support the finding that case element number two in Guoshi is not a cabinet?

[00:01:41] Speaker 01:
Yes, Your Honor.

[00:01:42] Speaker 03:
Are we talking about figure eight?

[00:01:46] Speaker 03:
Is that case two?

[00:01:47] Speaker 01:
Yes, Your Honor.

[00:01:48] Speaker 01:
The drawing of figure eight in the Guoshi patent

[00:01:53] Speaker 01:
shows the case two for encasing the LED display modules.

[00:01:58] Speaker 01:
So the key disclosure is, in Guoshi, that this case two encases the LED display module.

[00:02:06] Speaker 01:
Encasing means to enclose in, or as if in, a case.

[00:02:11] Speaker 03:
So Guoshi is telling us... But let me ask you, your position is a cabinet doesn't require doors, but doesn't it require a back?

[00:02:22] Speaker 01:
And a front?

[00:02:23] Speaker 01:
The cabinet does require enough structure to enclose the back in order to, according to the construction, provide protection.

[00:02:31] Speaker 01:
How about the front?

[00:02:33] Speaker 01:
Well, the cabinet is joined in its front to the LED display panel.

[00:02:40] Speaker 01:
So the way a cabinet works is that you have the modules in the front, and then you have a panel, you have a case attached to it, a cabinet attached to it.

[00:02:49] Speaker 01:
that encloses the back.

[00:02:50] Speaker 02:
I understand the construction of cabinet below that nobody disputed.

[00:02:54] Speaker 02:
It is an enclosure separate from the LED panel to protect the LED panel from the environment, including water.

[00:03:01] Speaker 01:
Yes, Your Honor.

[00:03:02] Speaker 02:
So I guess what I'm wondering here is when I look at Figure 8, how does Case 2 protect

[00:03:11] Speaker 02:
those LED panels from the environment, including water.

[00:03:16] Speaker 02:
And it seems like water can easily hit all those display panels that are open.

[00:03:24] Speaker 01:
So if Your Honor's referring to the front side of the panel, the cabinet is never- The business end of this device.

[00:03:31] Speaker 02:
Right.

[00:03:32] Speaker 01:
The way cabinets are used, they never protect the front of the panel.

[00:03:35] Speaker 01:
And the reason is simple.

[00:03:36] Speaker 01:
One would not be able to see the LEDs if they were covered by a cabinet.

[00:03:41] Speaker 01:
So a cabinet is used to protect the back, the part that is not facing out and the part which is not showing the display.

[00:03:49] Speaker 01:
So cabinets are always in the back.

[00:03:51] Speaker 01:
There's no dispute about that.

[00:03:52] Speaker 03:
Well, assuming you're right, if you're looking at drawing eight, the issue is it's a case if it doesn't have a back and a cabinet if it does.

[00:04:04] Speaker 03:
And you're saying we should assume, even though we can't see,

[00:04:09] Speaker 03:
any back, that there is a back there?

[00:04:11] Speaker 03:
Is that, if I summarize what the deal is?

[00:04:14] Speaker 01:
That is close, Your Honor.

[00:04:15] Speaker 01:
The issue, though, is the following.

[00:04:18] Speaker 01:
Because he says, well, she says, that it encases, and that means enclose, the fact that we can't see the back doesn't mean that there isn't a back there.

[00:04:28] Speaker 01:
And it wasn't the patent owner's burden to prove that this cabinet or this case is not a cabinet.

[00:04:38] Speaker 01:
it was, or that it is a cabinet, it was the petitioner's burden of proof to show

[00:04:45] Speaker 01:
the P tab, why this structure is not a cabinet.

[00:04:49] Speaker 03:
Well, I don't know about that.

[00:04:50] Speaker 03:
I mean, you've got the drawing.

[00:04:51] Speaker 03:
What we've got is the drawing.

[00:04:54] Speaker 03:
And the drawing does not show the back.

[00:04:56] Speaker 03:
If there were a back and if that were operative, one would assume the drawing could have shown it.

[00:05:00] Speaker 03:
But it doesn't.

[00:05:01] Speaker 03:
So it shows us what is a casing.

[00:05:04] Speaker 03:
And you will agree, I thought the difference between a cabinet and a casing was back or no back.

[00:05:09] Speaker 01:
No, Your Honor, I don't believe.

[00:05:11] Speaker 03:
It says it's encased.

[00:05:13] Speaker 01:
Your Honor, I don't believe there's any distinction between case or cabinet.

[00:05:16] Speaker 01:
We believe that the term case here, particularly where in the background of the invention, it discusses the fact that a case can provide waterproofing effect.

[00:05:26] Speaker 01:
And that's in paragraph 5 at appendix 1413, that he is acknowledging that cases are used to provide waterproofing effect.

[00:05:35] Speaker 01:
And that makes sense.

[00:05:36] Speaker 03:
Well, I guess maybe I'm just missing it.

[00:05:40] Speaker 03:
But the patent itself uses the term casing.

[00:05:45] Speaker 03:
So the claim is a case, and the claim construction was without a cabinet, but clearly with a case, because that's what the claim has, right?

[00:05:58] Speaker 01:
There's no distinction.

[00:05:59] Speaker 01:
The fact that Groschi uses the term case is not an attempt

[00:06:03] Speaker 01:
and has not been considered to be a way of distinguishing it from a cabinet.

[00:06:07] Speaker 01:
The question is only whether the case here is a cabinet because it encases the back.

[00:06:14] Speaker 01:
And the fact that there's some ambiguity regarding the view from the back.

[00:06:19] Speaker 01:
Groschi doesn't show us the back view.

[00:06:22] Speaker 01:
And the way that figure eight is shown, there very well may be a back to it, but we just can't see it.

[00:06:30] Speaker 01:
Because of his description,

[00:06:32] Speaker 01:
of a case as enclosing, and the fact that he says that cases provide waterproofing effect, that's sufficient evidence to show it's a cabinet unless the petitioners, by a preponderance of the evidence, can show why this does not enclose the back of the panel, why this does not function as a cabinet.

[00:06:50] Speaker 01:
And they failed to do that.

[00:06:52] Speaker 01:
Their own petition didn't even deal with the cabinet issue.

[00:06:56] Speaker 01:
And when we raised the cabinet issue in our patent owner response,

[00:07:00] Speaker 01:
The petitioners never provided any expert testimony or otherwise that would show that a person of ordinary skill in the art, when looking at this drawing, would conclude that there is no back or that otherwise it does not provide any waterproofing effect.

[00:07:15] Speaker 01:
It was their burden.

[00:07:16] Speaker 01:
And the only evidence that they brought to bear is that there was a picture of a cabinet

[00:07:21] Speaker 01:
describing what our expert called a typical cabinet, and it had doors.

[00:07:26] Speaker 01:
And they explained to the PTAB that since we don't see any doors, this is not a cabinet.

[00:07:31] Speaker 01:
Of course, doors has nothing to do with the construction that they agreed was appropriate.

[00:07:37] Speaker 01:
So the text of Guoxi and his description of this case is sufficient to show that it is a cabinet, and there has been no evidence presented on the other side

[00:07:50] Speaker 01:
from an expert or a person of ordinary skill that indicates that this case does not provide the protection from the environment, including water, that is required for a cabinet.

[00:08:03] Speaker 01:
Unless there are questions on cabinet, I'll move on to the second issue.

[00:08:07] Speaker 01:
The second issue before the court and the second issue, which is a basis for reversal, is the issue of whether

[00:08:18] Speaker 01:
whether there is a disclosure of a plastic casing.

[00:08:22] Speaker 01:
Under the 1050 IPR, which were anticipation grounds, the petitioners relied entirely on Guoshi for the proposition that Guoshi discloses a plastic casing, as required by independent claims 1 and 13.

[00:08:39] Speaker 01:
Now, it's undisputed that Guoshi does not explicitly disclose the material of the base 10 in the embodiment that the petitioner relied on.

[00:08:49] Speaker 01:
It's also undisputed that the petitioner did not contend that base 10 is inherently made of plastic.

[00:08:57] Speaker 01:
Rather, because in the background of the technology, Groschi disclosed that LED display modules in the prior art generally used plastic for the base, that that is sufficient for an anticipation ground.

[00:09:12] Speaker 01:
And we believe that is incorrect and inconsistent with the law.

[00:09:17] Speaker 03:
But Gosha doesn't need to inherently be plastic, but it does expressly disclose plastic bases, right?

[00:09:30] Speaker 01:
It only discloses the statement that an LED display module generally includes a plastic base.

[00:09:37] Speaker 01:
He says that in discussing the technology background at appendix 1413,

[00:09:42] Speaker 01:
paragraph 5.

[00:09:44] Speaker 01:
He doesn't disclose in any of the embodiments that are being relied on.

[00:09:48] Speaker 01:
After all, anticipation requires all the elements of the claim to be disclosed in a single embodiment and arranged as in the claims.

[00:09:56] Speaker 01:
And there is no discussion in the body of quotient.

[00:09:59] Speaker 03:
Could it satisfy obviousness?

[00:10:01] Speaker 01:
It could be sufficient evidence for obviousness in and of itself, but not anticipation.

[00:10:05] Speaker 03:
OK, so if it's obvious, then, I mean, even if we assume it's obvious, then, I mean, my question went to whether or not we even have to look at Kim at all.

[00:10:14] Speaker 03:
So whether you're right or wrong about Kim, it doesn't matter because the disclosure is sufficient in, I'm sorry, I can't pronounce the name, in the other thing we've been, in Goshi.

[00:10:26] Speaker 01:
Well, there are two issues there.

[00:10:27] Speaker 01:
The first one is for 1050, we don't need to look at Kim because Guoshi is argued to explicitly disclose for anticipation purposes plastic.

[00:10:39] Speaker 01:
So for those claims, Kim is not relevant and Guoshi isn't sufficient.

[00:10:44] Speaker 01:
Under the 1049 IPR, you have the disclosure of the use of plastic in the background.

[00:10:52] Speaker 01:
However, the combination with Guoshi and Kim

[00:10:55] Speaker 01:
uses Kim's teaching of attaching a power supply to the back of a panel such as the one disclosed by Guoxi.

[00:11:04] Speaker 01:
The issue is, however, that Kim teaches that attaching a power supply to plastic is difficult.

[00:11:11] Speaker 01:
And he talks about how to overcome that problem.

[00:11:14] Speaker 01:
So one thing he suggests is perhaps instead of having these power supplies on every module, he would have a larger power supply, which he would attach to a different element called

[00:11:25] Speaker 01:
to actually to a case.

[00:11:27] Speaker 03:
And how does Kim rise to the level of a teaching away under our case law?

[00:11:32] Speaker 03:
It says it discusses that there are difficulties in mounting a large power supply to a plastic frame.

[00:11:42] Speaker 03:
But it also notes that existing displays are generally housed in plastic frames.

[00:11:49] Speaker 03:
So how does this rise to the level of a teaching away?

[00:11:52] Speaker 01:
It rises to that level, Your Honor, because his solution

[00:11:55] Speaker 01:
for the difficulty of attaching a power supply to the back of the frame is to attach it to metal instead, not to attach to plastic.

[00:12:05] Speaker 01:
He says what we do here instead is that we have a metal piece that he calls a heatsink made of metal.

[00:12:12] Speaker 01:
It's made it directly to the back of the LED panel, the actual circuit board itself.

[00:12:16] Speaker 01:
There's no plastic there anymore.

[00:12:18] Speaker 01:
And the

[00:12:20] Speaker 01:
The power supply is mounted directly to that.

[00:12:23] Speaker 01:
And so he's teaching us, don't attach this to plastic.

[00:12:26] Speaker 01:
Don't use a plastic casing.

[00:12:28] Speaker 01:
Use metal.

[00:12:29] Speaker 01:
So he's taught.

[00:12:30] Speaker 02:
Kim said something about instead of using one single large power supply, use multiple smaller power supplies.

[00:12:37] Speaker 01:
Your Honor, I believe that that disclosure has been misconstrued.

[00:12:42] Speaker 01:
And let me explain it.

[00:12:43] Speaker 01:
So Kim discloses that.

[00:12:47] Speaker 01:
attaching a power supply to the LED module.

[00:12:50] Speaker 01:
One module is difficult using plastic, when it is plastic.

[00:12:56] Speaker 01:
And he talks about this at appendix 1440.

[00:12:59] Speaker 01:
And then he says, to solve the problem, you can attach a power supply to the case for the entire sector, in other words, for many panels in a sector, in order to supply current to a plurality of modules.

[00:13:14] Speaker 01:
But he says that large capacity power supply is a bad idea because it's too big.

[00:13:20] Speaker 01:
It makes the whole panel thicker and that's bad.

[00:13:22] Speaker 01:
And so he solves the problem instead by using the same power supply attached to each LED module.

[00:13:29] Speaker 01:
So it's not bigger or smaller, it's the same one, but it's attached using metal.

[00:13:35] Speaker 01:
So to the extent that the board misconstrued that, that's very significant because I believe it did misconstrued and we explained that in our briefing.

[00:13:43] Speaker 01:
So we're still using the same small power supply.

[00:13:45] Speaker 01:
We're just attaching it to the back with metal.

[00:13:48] Speaker 01:
And that teaching, it teaches away from this combination where you're going to take a power supply and attach it to Groschi, where Groschi is using plastic.

[00:13:59] Speaker 03:
You're well into your rebuttal.

[00:14:05] Speaker 00:
Nothing further.

[00:14:05] Speaker 00:
I'll reserve the rest of my time.

[00:14:07] Speaker 00:
Thank you.

[00:14:08] Speaker 00:
Good morning, Your Honors.

[00:14:09] Speaker 00:
I'm still Kevin Martin, still joined by Jordan Bach.

[00:14:12] Speaker 03:
You're so welcome.

[00:14:13] Speaker 00:
Thank you, Your Honor.

[00:14:16] Speaker 00:
So Your Honors, their argument on this IPR focuses on the cabinet issue and the plastic base issue, and I'll take them in that order.

[00:14:25] Speaker 00:
With respect to the cabinet issue, really the question is whether Guoshi discloses a panel that is sealed to be waterproof, the language of the claims, without reliance upon an exterior cabinet.

[00:14:36] Speaker 00:
And when you look at Gaoshi, the board properly concluded that Gaoshi teaches that its panels are sealed, not using a cabinet, but using elements of the panel itself, namely sealant that's poured over the panel, sealing strips and some caps that go on the back, not a separate cabinet.

[00:14:56] Speaker 00:
What Gaoshi says repeatedly is that by using those elements of the panel itself, waterproofing is achieved.

[00:15:03] Speaker 00:
So to give just a couple of examples,

[00:15:05] Speaker 00:
Appendix, page 1414, paragraph 17 of Hiroshi.

[00:15:10] Speaker 00:
It describes the use of sealant and sealing strips, and then says, in such a way, it can guarantee that the waterproofing level of this LED display module is above IP65.

[00:15:22] Speaker 00:
And similar statements are made throughout.

[00:15:25] Speaker 00:
Another example is at paragraph 27, paragraph 30, very similar language, describes the elements of the panel itself.

[00:15:33] Speaker 00:
And then says it gets you above IP 65, above IP 64.

[00:15:39] Speaker 00:
So now let's turn to this case two, which is the focus of their argument.

[00:15:44] Speaker 00:
Case two is not described as providing environmental protection, including protection from water.

[00:15:51] Speaker 00:
What the, what Kowashi says in discussing case two, it discusses it together with the panels themselves, the panels one.

[00:15:59] Speaker 00:
It says the LED Modules 1 have good waterproofing.

[00:16:04] Speaker 00:
There is no such statement made with respect to the Case 2.

[00:16:07] Speaker 00:
Case 2 is never described as providing any waterproof benefits.

[00:16:12] Speaker 00:
And there's a reason for that.

[00:16:13] Speaker 00:
As their own expert acknowledged during his deposition, this is at Appendix 1772, I have no knowledge of what the BAT comprises.

[00:16:24] Speaker 00:
He admits effectively that it could be open or closed.

[00:16:27] Speaker 00:
He doesn't know.

[00:16:29] Speaker 00:
So Gouoshi itself doesn't describe Case 2 as having any environmental benefits in noted contrast to the LED Modules 1, which are described as getting you above IP65.

[00:16:39] Speaker 00:
And their expert never testified that a postal looking at Case 2 would know that it was providing environmental benefits.

[00:16:48] Speaker 00:
There is the word encasing, which is used.

[00:16:51] Speaker 00:
Your Honor noted that case does not itself imply environmental benefits.

[00:16:56] Speaker 00:
The claims of the patent does not imply a cabinet.

[00:16:59] Speaker 00:
the claims of the patents themselves have a case.

[00:17:02] Speaker 00:
But that is not a cabinet, despite being a case.

[00:17:05] Speaker 03:
I think your friend says, though, that we've got the board decision under review, and that the board relied kind of exclusively on the lack of doors.

[00:17:17] Speaker 03:
And you seem to be arguing, no, no, no, no, no.

[00:17:20] Speaker 03:
Clearly, it was relying on more than that.

[00:17:22] Speaker 03:
So why don't you tell us about that?

[00:17:23] Speaker 00:
It was relying on more than that, Your Honor.

[00:17:24] Speaker 00:
When you look at the board's decision, what it does is explain

[00:17:28] Speaker 00:
that the Guoshi is focused on the use of sealant.

[00:17:34] Speaker 03:
Give us a page number.

[00:17:36] Speaker 00:
I'm looking at my notes right now.

[00:17:38] Speaker 00:
I know we have it in our brief.

[00:17:40] Speaker 00:
A30?

[00:17:41] Speaker 00:
A30.

[00:17:41] Speaker 00:
Guoshi focuses on waterproofing and protecting the LED display module without a case or cabinet using, quote, sealants that is poured on the circuit board and waterproof covers and sealing strips.

[00:17:54] Speaker 00:
and cooling units, A32, Gouoshi's written description unambiguously teaches waterproofing and cooling of the display module being incorporated into the display module itself and not because it is protected inside a waterproof cabinet structure.

[00:18:10] Speaker 00:
So the board was squarely focused on the fact that Gouoshi describes how to achieve waterproofing using elements of the panel itself and not a external cabinet.

[00:18:23] Speaker 00:
Now, again, the word encasing, when Gowoshi is talking about environmental benefits, in the context of a cabinet, it uses a different word, which is sealing, not encasing.

[00:18:33] Speaker 00:
And this is at 1413 paragraph five of Gowoshi, where it describes the use of a cabinet in the prior art and says that it involves sealing the panel in a case, not encasing it in a case.

[00:18:51] Speaker 00:
Um, we think that, um, the best view of that case too, is very similar to, um, frame 1310 in the hall patents, which is just a, a frame, which groups together modules, um, for purposes of grouping, um, but does not provide environmental benefits.

[00:19:08] Speaker 00:
If you look at, um... Are you telling us what you think?

[00:19:11] Speaker 03:
What did the board say?

[00:19:12] Speaker 03:
Did the board say any of that?

[00:19:13] Speaker 00:
I don't believe the board focused on that, your honor.

[00:19:16] Speaker 00:
Um, but this is additional support for the board's finding.

[00:19:20] Speaker 00:
If there are no further questions on the cabinet issue, Your Honor, I'll move on to the plastic issue.

[00:19:26] Speaker 00:
So with the plastic base, Guoshi states in the background of the technology that LED panels generally have.

[00:19:34] Speaker 00:
An LED module generally includes a plastic base.

[00:19:38] Speaker 00:
Guoshi never describes a different material for use in a base.

[00:19:42] Speaker 00:
And our expert testified and the board credited

[00:19:48] Speaker 00:
that a person of skill in the art would understand that a base for an LED module could be made of plastic.

[00:19:55] Speaker 00:
As I understand their principal argument, it's that Hiroshi does not repeat the statement that a base can be plastic when describing its own invention.

[00:20:06] Speaker 00:
However, I think between the combination of Hiroshi only disclosing plastic and never teaching away from plastic, the board had ample support for its conclusion that a person of skill in the art would understand

[00:20:16] Speaker 00:
that the base in Gaoshi could be plastic.

[00:20:19] Speaker 00:
There is, as we read the case law, no requirement that a prior art reference include all of the elements laid out in direct order.

[00:20:28] Speaker 00:
We pointed to Chamberlain versus Tectronic, which says that a reference can anticipate a claim, not just render a claim obvious, even if it does not expressly spell out all the limitations arranged or combined as in the claim.

[00:20:42] Speaker 00:
What matters is that a POSA reading

[00:20:45] Speaker 00:
The prior reference would at once envisage the claimed combination.

[00:20:52] Speaker 00:
And we think the board had ample support for its conclusion that that was the case here.

[00:20:56] Speaker 00:
With respect to the teaching away issue, the board again had support in the record under the substantial evidence standard for its conclusion that a post would understand that using smaller power supplies solves whatever plastic issue is raised in Kim.

[00:21:12] Speaker 00:
In addition to Kim's own discussion of using small power supplies, the board also took into account our expert's testimony and the teachings of Guoshi that using screws allows you to mount something to a plastic base.

[00:21:30] Speaker 00:
If there are no further questions, Your Honor.

[00:21:34] Speaker 03:
It appears not.

[00:21:35] Speaker 00:
Thank you.

[00:21:35] Speaker 03:
Thank you, Your Honor.

[00:21:36] Speaker 03:
Will we store two minutes of rebuttal if you need it?

[00:21:39] Speaker 01:
Thank you, Your Honors.

[00:21:41] Speaker 01:
With respect to the cabinet issue, counsel mentioned that there is nothing from a person of ordinary skill regarding whether a case meets the cabinet limitation.

[00:21:52] Speaker 01:
Our expert at Appendix 2018 opined that the case for encasing the LED modules meets the construction of a cabinet.

[00:22:03] Speaker 01:
That was unrebutted by any expert on the petitioner's side.

[00:22:07] Speaker 01:
There's an argument made that the case doesn't provide a waterproofing effect because Gwoshi talks about measures that are taken on the panel to provide a waterproofing effect.

[00:22:17] Speaker 01:
Now, most of what counsel mentioned were measures that are taken on the front of the panel, which is irrelevant to whether there's waterproofing on the back of the panel.

[00:22:25] Speaker 01:
The fact is that the back of the Gwoshi panel has openings.

[00:22:29] Speaker 01:
They're clear openings, and the court can see those openings.

[00:22:33] Speaker 01:
at Appendix 1422, those are openings that go directly to the back of the board so that wires for the power supply can be plugged in.

[00:22:45] Speaker 01:
There are some covers over those holes, but those are not completely sealed.

[00:22:49] Speaker 01:
And so the waterproofing on the back of the panel is at a lower rating than at the front.

[00:22:54] Speaker 01:
Groschi discloses that it's IP64, not IP65.

[00:22:58] Speaker 01:
And so Groschi puts a case on the back, I was going to say above

[00:23:02] Speaker 01:
It says above, but there's no above IP64 that reaches IP65 because they're completely different tests.

[00:23:09] Speaker 02:
IP64 test involves... Well, above 64 does not equate to 65.

[00:23:15] Speaker 01:
Yes, Your Honor, that's correct.

[00:23:18] Speaker 01:
And so the waterproofing on the back is inferior to the waterproofing in the front.

[00:23:23] Speaker 01:
And there's nothing in the construction that requires a cabinet to provide all the waterproofing on the panel or all the waterproofing in the back either.

[00:23:30] Speaker 01:
As long as it provides protection, then the case can meet the cabinet limitation.

[00:23:37] Speaker 01:
One issue on the Chamberlain case that was mentioned, in that case, there were two inventive environments.

[00:23:43] Speaker 01:
One inventive embodiment had a battery with a charger.

[00:23:45] Speaker 01:
The other inventive embodiment had a different battery without a charger.

[00:23:49] Speaker 01:
And the court found that you could take the charger and made it with the battery that didn't have a charger with it, and that would still meet anticipation.

[00:23:56] Speaker 01:
So we had inventive embodiments with all the claim elements disclosed.

[00:24:01] Speaker 01:
Whereas here in Goshi, there is no inventive embodiment in which Goshi says that his base in his embodiment is made of plastic.

[00:24:08] Speaker 01:
And so we don't think Chamberlain helps.

[00:24:13] Speaker 01:
Lest there are any questions, I'm over my time.