[00:00:01] Speaker 02:
Our next case is a novel part, LLC versus Target Corporation, 24-1545.

[00:01:16] Speaker 02:
Mr. Griggs, you're reserving five minutes.

[00:01:18] Speaker 02:
Is it time for rebuttal?

[00:01:19] Speaker 02:
Yes.

[00:01:19] Speaker 02:
Okay, we're ready to go.

[00:01:37] Speaker 00:
Morning.

[00:01:38] Speaker 00:
Michael Griggs from Boyle Fredrickson on behalf of Novaport.

[00:01:41] Speaker 00:
With me is Miriam Lynn, also Boyle Fredrickson.

[00:01:44] Speaker 00:
Also with me is John Pienkos, the inventor of the asserted patents, and also principal officer of Novaport.

[00:01:54] Speaker 00:
I'd like to address four points today.

[00:01:57] Speaker 00:
First, claim 15 of the 260 patent is not representative of all of the other asserted claims.

[00:02:06] Speaker 00:
Second,

[00:02:07] Speaker 00:
When you do look at these other asserted claims in the detail that is required, those claims are not directed to an abstract idea.

[00:02:18] Speaker 02:
Third.

[00:02:19] Speaker 02:
Let's assume, just for the argument, that it is representative, and go ahead and address the Section 101 issues.

[00:02:28] Speaker 00:
Address the Section 101 issues, assuming that Claim 15 is representative?

[00:02:35] Speaker 00:
Correct.

[00:02:36] Speaker 00:
Sure, with respect to the abstract idea under step one.

[00:02:45] Speaker 00:
I'd like to address those in the context of those other claims, because I believe there is a distinctive significance between claim 15 and 215.

[00:02:58] Speaker 02:
Address claim 15 and assume that that's representative of all the claims.

[00:03:03] Speaker 02:
Sure.

[00:03:04] Speaker 02:
And then give us your Section 101 argument.

[00:03:07] Speaker 00:
Section 101 argument on claim 15, sure.

[00:03:11] Speaker 00:
With respect to abstractness,

[00:03:14] Speaker 00:
I think important with respect to claim 15 and the remainder of the claims that are at issue here, it's important, as recognized in Bascom, that you need to look at the combination of the elements as a whole.

[00:03:26] Speaker 00:
A lot of what Target has set forth is they parse the claims and they pick out individual components and argue that those are conventional or well-known and that the claims recite nothing more.

[00:03:38] Speaker 00:
But I would submit, including with respect to claim 15,

[00:03:42] Speaker 00:
that when you look at the ordered combination of those limitations, it recites more than an abstract concept.

[00:03:49] Speaker 00:
With respect to claim 15, when you look, I would have you focus on the clause where it talks about the type of data that is stored in the system, in the database.

[00:04:01] Speaker 02:
Well, Counselor, I look at claim 15, and I see the following.

[00:04:06] Speaker 02:
Collecting, analyzing, receiving, retrieving, presenting information.

[00:04:12] Speaker 02:
It's manipulating information.

[00:04:15] Speaker 02:
And our past case law says that those types of claims are directed to an abstract idea.

[00:04:22] Speaker 02:
Can you address that?

[00:04:24] Speaker 00:
Certainly.

[00:04:24] Speaker 00:
And again, this is under the assumption that claim 15 is representative, which a novel court disagrees with.

[00:04:31] Speaker 00:
But if we are just looking at the claim language of claim 15,

[00:04:35] Speaker 00:
I think you also have to consider the context in which this claim is presented with respect to the retail environment.

[00:04:41] Speaker 00:
The claim is not written in such an abstract matter that it would apply beyond that.

[00:04:47] Speaker 00:
And you also have to consider the state of the art at the time with respect to this claim and what was being done.

[00:04:53] Speaker 00:
And I believe what Your Honor just recited is an overgeneralization of that claim.

[00:04:58] Speaker 00:
And I would get back into the claim language itself.

[00:05:01] Speaker 00:
For example.

[00:05:03] Speaker 00:
with respect to the types of information that is being stored in the system and the way it is stored.

[00:05:09] Speaker 00:
It recites, I believe, about four different types of product-related information.

[00:05:14] Speaker 00:
It will talk about the price of the product, the availability of the product.

[00:05:19] Speaker 00:
There's information in Claim 15 about cross-linking one product with another or linking one product with another product.

[00:05:27] Speaker 00:
in a cross-linking passion.

[00:05:31] Speaker 03:
The one concern I have is why isn't this just using computers in a way computers would conventionally be used?

[00:05:40] Speaker 03:
I mean that is what one thing we think about with these abstract idea cases is how do you assert that this is a technological innovation?

[00:05:50] Speaker 03:
What is your basis for that?

[00:05:51] Speaker 00:
Certainly.

[00:05:52] Speaker 03:
And for me, I wouldn't necessarily agree that claim 15 is representative.

[00:05:58] Speaker 03:
So for answering this question, you can address the other claims if you want to.

[00:06:04] Speaker 00:
Certainly.

[00:06:04] Speaker 00:
Thank you.

[00:06:06] Speaker 00:
And maybe I would use the eco-services case as a somewhat analogous case as a starting point, which again, when you look at the technical advance, what are we advancing over?

[00:06:17] Speaker 00:
What is the state of the art at the time?

[00:06:19] Speaker 00:
And as the specification of these patents explains, you know, the predominant method, and I think everybody's probably experienced this before, going into a store and trying to find a product.

[00:06:29] Speaker 00:
And I think it is also important to place yourself back in 1999, before everybody had smartphones and computers in their pocket.

[00:06:37] Speaker 00:
And so that's an important lens through which you have to do this analysis.

[00:06:42] Speaker 00:
And so back to your question, what is the technical advance here?

[00:06:46] Speaker 00:
when you consider the state of the art at the time as going in to ask a store clerk who you may or may not be able to find, who may or may not have any information that may be helpful.

[00:06:57] Speaker 00:
And this is sort of similar to the eco-services case in that that was about washing jet engines, and it had been done by people, and they had their own ways of doing it and evaluating what needed to be cleaned.

[00:07:10] Speaker 00:
And so what this court recognized in equal services, which I think is also applicable here, is this is an entire new system.

[00:07:17] Speaker 00:
This isn't something where you're just integrating one computer component into an existing system.

[00:07:24] Speaker 00:
The entire system itself was an advance over how things had been done.

[00:07:29] Speaker 04:
So you agree, though, that this is something that could be done using pure human activity as well, right?

[00:07:36] Speaker 04:
I recognize that.

[00:07:37] Speaker 04:
You're saying that the alleged or reported invention involves doing it on a computer.

[00:07:42] Speaker 04:
But couldn't this also be paralleled via human activity?

[00:07:48] Speaker 00:
Could it be done using human activity?

[00:07:51] Speaker 00:
I mean, it's possible.

[00:07:52] Speaker 00:
I guess the question more is, was it being done in any sort of similar fashion?

[00:07:58] Speaker 02:
Just the other day, I was in the grocery store.

[00:08:01] Speaker 02:
And I forgot what I was looking for.

[00:08:03] Speaker 02:
But I couldn't find it.

[00:08:05] Speaker 02:
And I asked a couple of people.

[00:08:07] Speaker 02:
And one lady led me.

[00:08:09] Speaker 02:
She not only told me what aisle it was in, but she actually walked me over and pointed it to it.

[00:08:15] Speaker 02:
That's what this pen does.

[00:08:19] Speaker 00:
It does that, yes, but it also does other things.

[00:08:24] Speaker 00:
For example, providing a suggestion.

[00:08:26] Speaker 02:
Those other things that it does, it does it by collecting information, manipulating the information, storing information.

[00:08:36] Speaker 00:
That's a component of it.

[00:08:38] Speaker 00:
Yes.

[00:08:38] Speaker 00:
Guess what?

[00:08:39] Speaker 00:
I said that is a component of it.

[00:08:40] Speaker 00:
But I think what we're talking about right here demonstrates that it takes it out of the realm of abstraction.

[00:08:47] Speaker 00:
It's something more than this.

[00:08:50] Speaker 03:
How so?

[00:08:52] Speaker 00:
It depends on the level.

[00:08:54] Speaker 00:
If you're just abstracting this down to collecting data, organizing it, and then presenting it, which is how Target has characterized it and how the district court below characterized it, it's more than that.

[00:09:08] Speaker 00:
For example, if you look at the claims in the 670 and the 690, I won't get into the detail.

[00:09:16] Speaker 00:
But during prosecution, there was the 101 rejection under 101, and these specific limitations were included to overcome that 101 rejection.

[00:09:25] Speaker 04:
But you know we're not bound by what the Patent Office did in terms of that, right?

[00:09:29] Speaker 04:
So if we are going to break it down into Alice Step 1 versus Alice Step 2, can you tell me what the alleged inventive concept is?

[00:09:37] Speaker 04:
assuming that we conclude on all step one is directed to an abstract idea.

[00:09:42] Speaker 00:
Certainly.

[00:09:42] Speaker 00:
And again, I go back to Bascom and the ordered combination.

[00:09:46] Speaker 00:
So we're not just pointing to a single limitation.

[00:09:48] Speaker 00:
You have to look at what the claims are reciting as a whole against the backdrop of what was being done at the time, which is predominantly asking a store clerk.

[00:09:58] Speaker 03:
But again, I'm sorry to interrupt you, but I just want to make sure you have a full understanding of what I'm saying so you can address it now, which is that, you know,

[00:10:11] Speaker 03:
We have been told by the Supreme Court that if you just have a claim that's directed to do it on a computer, then that will not be eligible.

[00:10:21] Speaker 03:
But if there's a technological advantage, a technological solution to a technological problem, then your claim might be eligible.

[00:10:31] Speaker 03:
So I want to know, what is the technological solution?

[00:10:33] Speaker 03:
You seem to be talking about, well, you can grab this data and that data and this data and provide it.

[00:10:38] Speaker 03:
But that doesn't sound like a technological solution to a technological problem.

[00:10:44] Speaker 00:
Sure.

[00:10:45] Speaker 00:
So the technological problem at the time was having customers being able to submit a real-time inquiry using a system, for example, a mobile device or a kiosk.

[00:10:59] Speaker 00:
If information returned in a rapid manner that is accurate and correct, and in addition to that,

[00:11:08] Speaker 00:
what, for example, the claims of the 670690 patent get into is making a suggestion relating to a product that was not the subject of an inquiry, which goes above and beyond.

[00:11:19] Speaker 00:
But as far as the technological aspect, again, sort of like the ecosystems case, it's the entire system.

[00:11:28] Speaker 00:
It's using this type of system, allowing a person to have a mobile device

[00:11:33] Speaker 00:
in a store that they can use to search for products, as opposed to trying to find a person who you may not be able to find and who may not have the information that you're looking for.

[00:11:46] Speaker 02:
If you do find the person, or you use a mobile device to find the product, you've essentially done the same thing.

[00:11:56] Speaker 02:
There's no difference between asking a clerk, where's the butter,

[00:12:00] Speaker 02:
And then looking up in your device and punching in the butter.

[00:12:05] Speaker 00:
Yeah.

[00:12:05] Speaker 00:
Well, and I guess I would point to your honor's use of the word if with respect to the clerk.

[00:12:09] Speaker 00:
Because as contemplated by this system, you will always be able to find the butter.

[00:12:16] Speaker 00:
You may not always be able to find a clerk.

[00:12:18] Speaker 00:
And maybe the clerk doesn't know if the butter's there.

[00:12:20] Speaker 00:
Maybe the clerk doesn't know if the type of butter you want is in stock.

[00:12:23] Speaker 02:
And so that's the practical application of this, is how, in answer to Joe Stowell's question, how is that a technological issue, resolving a technological problem with technology?

[00:12:38] Speaker 00:
Well, I think when you're looking at the retail market, that's the environment that we're dealing with here.

[00:12:46] Speaker 00:
This type of system just didn't exist.

[00:12:49] Speaker 00:
These patents are the first time this type of system was invented.

[00:12:53] Speaker 00:
And so as I said before, it's not as if there

[00:12:56] Speaker 00:
there was already some system in place that this is an advance over.

[00:13:01] Speaker 00:
This is an advance over these interactions with store clips.

[00:13:05] Speaker 00:
Can I ask a few housekeeping questions?

[00:13:08] Speaker 00:
Sure.

[00:13:09] Speaker 04:
Thank you.

[00:13:10] Speaker 04:
Do you make any arguments for claim one of the 670 patent that do not apply to claim one of the 690 patent, or vice versa?

[00:13:19] Speaker 00:
No, those rise and fall together.

[00:13:20] Speaker 00:
OK, that's helpful.

[00:13:21] Speaker 04:
And then also, would you agree that in

[00:13:26] Speaker 04:
In addition to claim 15, the district court also looked at claim 1 of the 9-3-3 patent, right?

[00:13:35] Speaker 00:
It did.

[00:13:36] Speaker 00:
I would characterize that as impassable.

[00:13:40] Speaker 04:
In terms of your kind of representiveness argument, you would agree that, of course, a court can pick

[00:13:48] Speaker 04:
a claim or more than one claim in terms of representiveness.

[00:13:51] Speaker 04:
You just wanted, in this instance, for there to be more claims picked, as opposed to just relying on claim 15 of the 260.

[00:13:58] Speaker 04:
Is that right?

[00:13:59] Speaker 00:
Correct.

[00:13:59] Speaker 00:
In all the cases I reviewed, the courts do use representative claims.

[00:14:03] Speaker 00:
But I have not seen it where you pick one claim as representative across six patents, representative of 55 other claims.

[00:14:10] Speaker 00:
The Data Engines case, for example, gets into that a little bit, using representative claims from different patents, but recognizing that there are

[00:14:17] Speaker 00:
different limitations recited that do impact the analysis.

[00:14:21] Speaker 03:
Do I understand correctly that I think you've identified maybe four representative claims?

[00:14:26] Speaker 00:
Yes.

[00:14:26] Speaker 00:
I believe when you look, the 670, the 690 claim one out of the 933 patent.

[00:14:34] Speaker 00:
And then there's the 315 and 380 patents, which are directed to systems and kiosks, which are, frankly, quite different than claimed 15 of the 260 patents.

[00:14:46] Speaker 00:
And if the court were to look and to determine the representative claim, I would focus the court's attention on those claims.

[00:14:53] Speaker 04:
Do the 315 and 3AO patents claims that rise and fall together like you told me with respect to the 670 and the 690?

[00:15:00] Speaker 00:
You know, I would have to look more closely.

[00:15:03] Speaker 00:
I would tentatively say yes.

[00:15:05] Speaker 00:
I think those are generally directed.

[00:15:06] Speaker 00:
And again, it's sort of a different bucket, right?

[00:15:08] Speaker 00:
It's just a different type of an invention.

[00:15:12] Speaker 04:
That's it for my housekeeping.

[00:15:14] Speaker 00:
OK, thank you.

[00:15:14] Speaker 00:
All right, thank you.

[00:15:21] Speaker 02:
Councillor Wyatt.

[00:15:24] Speaker 01:
May it please the court.

[00:15:25] Speaker 01:
Lance Wyatt on behalf of Appellee Target Corporation.

[00:15:29] Speaker 01:
Unless the court has any initial questions, I'd like to touch on the claim representativeness issue.

[00:15:36] Speaker 01:
Here, the court found that claim 15 of the 260 patent is representative.

[00:15:43] Speaker 01:
And there was no distinctive significance compared to all of the other claims.

[00:15:51] Speaker 01:
Anovaport points to about three different limitations and focuses on those limitations.

[00:15:56] Speaker 01:
The first being a suggestion related to another product that's in the 670 and the 690 patent.

[00:16:03] Speaker 01:
And then a suggestion based on the user's past history from the 933 patent.

[00:16:09] Speaker 01:
And then finally, incorporation of a mobile device as the user interface from the 670 and the 690 patent.

[00:16:18] Speaker 01:
All of these claims are directed to the same abstract idea.

[00:16:24] Speaker 01:
Suggesting a product or another product is really almost implicitly in claim 15 of the 260 patent.

[00:16:33] Speaker 03:
On appeal, are we able to just look at each of those individually and come to the conclusion that they don't satisfy either step one or step two and not worry about the representativeness of the claims and instead consider all of them?

[00:16:49] Speaker 01:
Yes, Your Honor, it is a de novo review.

[00:16:51] Speaker 01:
And this is an issue of law.

[00:16:54] Speaker 01:
And here, claim 15 of the 260 patent.

[00:17:01] Speaker 01:
does provide additional product information.

[00:17:05] Speaker 01:
Now, there's different language that is used in the 670 and the 690 patent, which relates to a suggestion to another product.

[00:17:13] Speaker 01:
But providing information of another product isn't really distinctive.

[00:17:18] Speaker 01:
There's no distinctive significance compared to suggesting another product.

[00:17:22] Speaker 01:
Those are still related to the same abstract idea.

[00:17:27] Speaker 04:
Additionally, one of the arguments that opposing counsel is making, at least in the briefing, is that with respect to the Lowe's case, I think there was a different outcome on it, and it was at a different stage, right?

[00:17:40] Speaker 04:
It was at the 12-6 stage.

[00:17:42] Speaker 04:
What is your response to just that different outcome in the Lowe's case versus the outcome here in terms of the summer judgment stage?

[00:17:52] Speaker 01:
Yes, Your Honor.

[00:17:52] Speaker 01:
So that was the same judge down below.

[00:17:56] Speaker 01:
And in the Lowe's case, the issue at step one was that Lowe's

[00:18:01] Speaker 01:
incorrectly or improperly characterized the abstract idea.

[00:18:05] Speaker 01:
It did not focus or include the additional information that's provided beyond the product location information.

[00:18:11] Speaker 01:
So that was the issue that the court criticized at step one that we overgeneralized or Lowe's overgeneralized the abstract idea for failing to acknowledge or

[00:18:23] Speaker 01:
even confront this additional product information.

[00:18:26] Speaker 01:
But the court didn't actually make a determination at step one and say, I've looked at these claims, and it is directed to an abstract idea, or it is not directed to an abstract idea.

[00:18:38] Speaker 01:
It merely just rested on Lowe's made an improper characterization at step one, and then moved to step two and said this idea of providing additional information, at least facially,

[00:18:51] Speaker 01:
We don't have a developed record, but at least facially, could be an inventive concept.

[00:18:56] Speaker 01:
But we need a more developed record to determine whether that's the case.

[00:19:01] Speaker 01:
Here, we got to summary judgment.

[00:19:03] Speaker 01:
We had a closed record.

[00:19:05] Speaker 04:
And in characterizing the abstract, I- Was fact discovery all concluded by the time you got to summary judgment, just in terms of what had happened in terms of the timeline of the case?

[00:19:16] Speaker 01:
Yes.

[00:19:16] Speaker 01:
So fact discovery had concluded that the

[00:19:19] Speaker 01:
The lower court's scheduling order was a little odd, if you will, because the fact discovery deadline actually came behind briefing on summary judgment.

[00:19:31] Speaker 04:
When you say behind, after?

[00:19:34] Speaker 01:
After summary judgment briefing.

[00:19:35] Speaker 01:
So it was a little odd to have summary judgment briefing and then have a later deadline for fact discovery.

[00:19:40] Speaker 01:
But I think Mr. Griggs would agree that the parties had completed fact discovery by the time of summary judgment briefing.

[00:19:48] Speaker 01:
So turning back to the Lowe's case, at step two, the court found that this additional product information that's provided could, at least facially, provide an inventive concept.

[00:20:01] Speaker 01:
In this case, at step one, Target incorporated the additional product information into the abstract idea.

[00:20:08] Speaker 01:
The court agreed with that characterization.

[00:20:11] Speaker 01:
And then at step two,

[00:20:13] Speaker 01:
Looking at the additional product information as an inventive concept, the court concluded that it's an abstract idea and the abstract idea cannot provide the inventive concept because here you're just providing different type of information.

[00:20:27] Speaker 01:
You have information related to product location and also information related to price of the product, quantity of the product, maybe another product, but it's still just providing information in response to a user's query.

[00:20:45] Speaker 01:
So just going back briefly to the claim representative analysis, the mobile device being used as the user interface, first of all, the 260 patent, claim 15, does recite a user interface.

[00:21:03] Speaker 01:
And the specification has both user interfaces that are mobile devices and stationary devices.

[00:21:11] Speaker 01:
What's interesting is the mobile device that's characterized in the specification, there was some discussion in the briefing that this had to be smartphones.

[00:21:21] Speaker 01:
And smartphones weren't around until 2007, 2008.

[00:21:23] Speaker 01:
That's not what the specification says in regards to a mobile device.

[00:21:28] Speaker 01:
In the 260 patent at column 14, lines 39 through 44, at appendix 63,

[00:21:36] Speaker 01:
It states that further embodiments of the invention that include additional capabilities tailored to the needs of the individual customer are possible through the use of handheld or otherwise mobile, preferably wireless, devices.

[00:21:50] Speaker 01:
This is column 14, lines 39 through 44 on appendix 63.

[00:22:00] Speaker 01:
And the second sentence there says, such devices can include, for example, telephone or walkie-talkie type units, headphones, specialized eyewear.

[00:22:09] Speaker 04:
Appendix 63 has columns 15 and 16.

[00:22:11] Speaker 04:
I'm not sure if I'm... As long as I'm... Let me make sure I'm... You want me to look at.

[00:22:16] Speaker 01:
I might have had the wrong... Incorrect.

[00:22:20] Speaker 01:
Okay, it's Appendix 62.

[00:22:21] Speaker 01:
My apologies, Your Honor.

[00:22:23] Speaker 01:
And then... Column 14.

[00:22:25] Speaker 01:
Lines... Lines 39 through 44.

[00:22:27] Speaker 01:
Okay, thank you.

[00:22:36] Speaker 01:
So whether you look at claim 15 of the 260 patent as representative of all the claims, or you look additionally to the additional limitations and additional claims pointed out by Inovaport, they are all directed to the same abstract idea.

[00:22:55] Speaker 01:
They all take the longstanding human activity of interacting with clerks in a store and provide off-the-shelf computer technology

[00:23:05] Speaker 01:
performing conventional functionality to accomplish that abstract idea.

[00:23:11] Speaker 01:
So unless the court has any further questions, I'll stand.

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

[00:23:15] Speaker 01:
Thank you.

[00:23:18] Speaker 02:
We've got three minutes.

[00:23:28] Speaker 00:
Thank you.

[00:23:28] Speaker 00:
I'd like to address a couple of points

[00:23:32] Speaker 00:
When I was up here before, we were talking about the technological advance.

[00:23:36] Speaker 00:
And I guess I would just like to remind the court that

[00:23:40] Speaker 00:
at the 101 stage, which is just a threshold issue.

[00:23:44] Speaker 00:
And I don't believe it should be that high of a bar to get over.

[00:23:49] Speaker 00:
We're looking at what the claims are directed to, right?

[00:23:52] Speaker 00:
We're not considering whether it actually is a technical advance.

[00:23:57] Speaker 00:
It's whether that's what is identified as a technological advance and that the claims are directed to those.

[00:24:03] Speaker 00:
Whether that is a technological advance is a question for 102 and 103.

[00:24:07] Speaker 02:
So you're saying that there is no technological advance here?

[00:24:11] Speaker 00:
I'm sorry?

[00:24:12] Speaker 02:
There is no technological advance here in this case.

[00:24:16] Speaker 00:
No.

[00:24:16] Speaker 00:
We are asserting that when you look at the ordered combination in comparison with the state of the retail market environment in 1999, at the time that the specification was filed and the priority date,

[00:24:34] Speaker 00:
There was nothing like this system, like I said, sort of like the eco-services case.

[00:24:37] Speaker 00:
It was an entirely new system and a way to use this type of technology that greatly improved over the system, if you want to call it, which was interacting with people at stores.

[00:24:49] Speaker 00:
I'd like to move on to another point that I don't want to get lost in this with respect to how the court's going to handle this and these issues here.

[00:24:58] Speaker 00:
And it relates to step two.

[00:25:01] Speaker 00:
As the court is probably aware, the district court made a finding with respect to what is well understood, routine, and conventional regarding the use of kiosks, citing to the Rowley reference.

[00:25:18] Speaker 00:
As we pointed out in our briefs and is recognized in Berkheimer, that's a factual question.

[00:25:26] Speaker 00:
So at the very least, it was inappropriate for the district court to resolve that issue on summary judgment.

[00:25:32] Speaker 00:
That's a factual question that should go to the jury.

[00:25:36] Speaker 00:
As we said, Rowley actually stands for the countervailing point that the district court cited it for.

[00:25:42] Speaker 00:
Rowley called the use of kiosks in the retail environment in stores rare and experimental at the time, which- You didn't raise this argument in your opening statement or your opening argument, did you?

[00:25:54] Speaker 00:
No, I did not.

[00:25:55] Speaker 00:
Correct.

[00:25:56] Speaker 02:
So it's not fair to do it now.

[00:25:58] Speaker 00:
Correct.

[00:25:58] Speaker 00:
Thank you.

[00:26:01] Speaker 00:
So unless the court has any other questions, that's all I have.

[00:26:06] Speaker 00:
Thank you.

[00:26:07] Speaker 00:
Thank you.

[00:26:08] Speaker 02:
We thank the parties for their arguments for taking this case under submission.