[00:00:00] Speaker 03:
Our final case this morning is number 241540, Largan Precision Company versus Motorola Mobility.

[00:00:08] Speaker 03:
Mr. Russell?

[00:00:10] Speaker 00:
Good morning.

[00:00:12] Speaker 00:
May it please the court.

[00:00:12] Speaker 00:
Kevin Russell on behalf of Appellant Largan Precision Company Limited.

[00:00:16] Speaker 00:
The board in this case made two errors of law that require vacating its decision.

[00:00:21] Speaker 00:
First, the board refused to apply this court's genus species framework on grounds Motorola declines to defend in this court.

[00:00:29] Speaker 00:
That error, led it to, among other things, failed to take into account considerations like predictability in the art that this court's cases require, but the board did not do, because it didn't believe that those cases applied, committing the same error that this court reversed in Bilstead versus Wachalopolis.

[00:00:46] Speaker 00:
Second, to the extent the board suggested that this patent fails written description even under the genus species framework, because the specification disclaimed the full scope of the genus,

[00:00:57] Speaker 00:
That was wrong, too, because it failed to recognize that the disclaimer must be clear and unambiguous, a finding that it did not make.

[00:01:04] Speaker 00:
Instead, the court applied, the board applied, an essential element test that it derived from Gentry Gallery that this court has repeatedly rejected as a misreading of that case and a misapplication of the law.

[00:01:16] Speaker 00:
With respect to the first year, the board concluded that the genus species framework did not apply here because there are only a relatively small number of species in the genus.

[00:01:25] Speaker 00:
Motorola does not defend

[00:01:27] Speaker 00:
that conclusion in this court.

[00:01:29] Speaker 00:
And, in fact, it is quite wrong for the reasons we explained in our brief, but I think you can take it as conceded at this point.

[00:01:35] Speaker 03:
Instead, Motorola argues that any error was harmless because the genus species... But you have a situation here in which the specification says positive-negative alignment is what's involved here, and it has particular benefits.

[00:01:53] Speaker 03:
And now they're saying that that's sufficient description for a negative positive one.

[00:01:59] Speaker 03:
Correct?

[00:01:59] Speaker 00:
Correct.

[00:02:00] Speaker 03:
Well, I don't understand how that can be the case.

[00:02:04] Speaker 00:
Well, that is the question that the genus species case is asked.

[00:02:07] Speaker 03:
But first of all... Well, the genus species, it has to be representative.

[00:02:10] Speaker 03:
I don't understand how that can be representative when they say the particular features of the single species are what the invention is.

[00:02:21] Speaker 00:
Well, I think that would be a reason for you to think that the board might, if it had properly applied the genus thesis case, either find that there wasn't a representative sample shown or that there was a disclaimer here.

[00:02:32] Speaker 00:
But the board didn't make either of those findings because it didn't apply the correct test.

[00:02:36] Speaker 00:
And it expressly disavowed applying that test and asking whether this was representative.

[00:02:41] Speaker 00:
And it is black letter APA law.

[00:02:43] Speaker 00:
that when the board misapplies the legal standard, you have to send it back for it to apply in the first instance.

[00:02:48] Speaker 00:
And I understand that much of what it had to say in this case would be relevant under the proper legal standard.

[00:02:54] Speaker 00:
And it could even lead it to reach the same conclusion on remand.

[00:02:57] Speaker 00:
But we're entitled to have a chance to persuade the board that we should prevail under the right legal standard.

[00:03:03] Speaker 00:
And even more importantly to us, the harm from the board's analysis in this case isn't just the invalidation of these patents.

[00:03:09] Speaker 00:
but it is the threat that it has the lens design patents, generally, because it's always going to be possible to identify some variation of a lens design that isn't described in the specification.

[00:03:20] Speaker 00:
And it will frequently be possible to identify something in the description that is there and claim that it is an essential feature.

[00:03:28] Speaker 01:
Is there a much simpler reading of what the board is saying?

[00:03:32] Speaker 01:
Aren't they just making a factual finding that the 2012 written description would not have convinced one of ordinary skill in the art that the inventor possessed the lens agnostic or power agnostic embodiment in the first two lenses?

[00:03:49] Speaker 00:
I think that that is a reading of what they said.

[00:03:51] Speaker 00:
But this court's genus species cases tell the court how it has to tell the board how the steps it has to go through in order to answer that question.

[00:03:59] Speaker 00:
That is the ultimate written description question.

[00:04:02] Speaker 00:
But this court has developed a subgenre of cases and rules.

[00:04:06] Speaker 01:
And I don't understand where, I mean, what case can you cite where we have said,

[00:04:11] Speaker 01:
in the face of, from a board, a clear factual finding that one of ordinary skill in the art, as a matter of fact, would not have seen adequate written description for your current claims that are being challenged, that it makes any difference whether the board goes to genus species, goes to the gentry case, or just relies on that factual finding.

[00:04:38] Speaker 00:
So in Bill Stabb, the court reversed.

[00:04:41] Speaker 00:
of the board for not taking into account, for example, predictability in the ARBs.

[00:04:46] Speaker 00:
In Inray Global IP, another case that we cited, the board specifically declined to consider predictability, and this court reversed for that reason.

[00:04:55] Speaker 00:
But even stepping back a little farther, it's hard to imagine why the court would develop a body of law about what should be considered in a genus species case, which is what the court did in Ariat M. Bank.

[00:05:05] Speaker 00:
If it intended that to simply be an optional exercise, that you can just jump to the final conclusion even if you don't, wouldn't have recite conclusion had you gone through the steps that the genus species analysis requires.

[00:05:18] Speaker 00:
And the predictability in the arts here is not a trivial thing.

[00:05:23] Speaker 00:
is helpful for figuring out whether somebody would understand that the undescribed version of the invention is, in fact, possessed by somebody, because he would have understood that the undescribed element is not important or is not part of the invention.

[00:05:41] Speaker 00:
And we tried to make these kinds of arguments to the board.

[00:05:43] Speaker 00:
We argued and addressed at page 18 through 19 our arguments about what would predictably happen if you reverse the polarity of the first two lenses.

[00:05:51] Speaker 00:
But the board refused to consider that as an opposite because we didn't have a description of that version of the device in the specification.

[00:06:02] Speaker 00:
And so to the extent that Motorola's argument is simply that the board can skip over the genus species analysis, I don't think there's any support for that.

[00:06:12] Speaker 00:
And again, I don't see why the court would have bothered to go through developing this body of law.

[00:06:17] Speaker 00:
It was going to be simply optional.

[00:06:20] Speaker 00:
With respect to the possibility, as I admitted before, that a lot of the things that the board considered here could be taken into account under a proper genus species analysis.

[00:06:29] Speaker 00:
We don't dispute that.

[00:06:30] Speaker 00:
We're not asking this court to engage in substantial evidence review.

[00:06:34] Speaker 00:
Our ask here is simply to do the typical thing that the court does when there is a legal error with a court

[00:06:41] Speaker 00:
determines whether the board applied the proper legal standard here.

[00:06:44] Speaker 00:
You don't have to guess what standard they applied.

[00:06:46] Speaker 00:
They expressly disavowed applying the Dean of Species cases.

[00:06:50] Speaker 00:
And if that's wrong, if Motorola is wrong that this is just a labeling exercise, then I think the only thing the court has to do and the only thing it can do

[00:06:58] Speaker 00:
is send it back to the board to reconsider under the proper legal analysis.

[00:07:02] Speaker 00:
And if the board at this court were to do that, it may be that the board would reach the same conclusions for the reasons that.

[00:07:07] Speaker 03:
How could they do anything but that?

[00:07:09] Speaker 03:
I mean, there's all this discussion about the particular benefits of the positive negative alignment.

[00:07:15] Speaker 03:
How could that be representative of another genus that included the opposite?

[00:07:23] Speaker 03:
So I think that is a point in Motorola's favor in favor of a disavowal or disclaimer finding, but the board did not recognize that the disclaimer required under... You're asking for a remand because you said he didn't dot the I's and cross the T's and talk about how this could be representative of a genus including the opposite alignment.

[00:07:44] Speaker 03:
And I'm asking you, given this record, how could the board reach any conclusion that the positive negative alignment was a representative species for the opposite embodiment?

[00:07:57] Speaker 00:
because the board could and we did argue to the board that that was not, for example, the patentable feature of the lens system, that in fact what distinguished it from the prior art was the third and fifth lenses, and that somebody would have understood that the configuration of the doublet was not what the invention was about, and that we also cited to their own experts

[00:08:19] Speaker 00:
who testified that the reversal of the polarity of the first lens had the effect of changing it from telephoto to a wide angle system.

[00:08:27] Speaker 00:
And somebody who understood that, who understood that to be a predictable consequence of doing that in this particular lens system, could conclude that there was possession.

[00:08:37] Speaker 00:
But at the end of the day, you know,

[00:08:39] Speaker 00:
I think that these are facts that tend to go to a suggestion that maybe Your Honor thinks that had they applied the right standard, had they asked the representative sample question, had they asked the right disavowal question, that the board would have reached the same conclusion.

[00:08:53] Speaker 00:
But that is not a basis for affirmance here.

[00:08:56] Speaker 00:
And it's particularly important, to the extent you think that some of this information suggests that there was a disclaimer of the sort that there was in Gentry Gallery, that this court made clear, as it has time and time again, such a disclaimer.

[00:09:08] Speaker 03:
I don't see Gentry Gallery resting on a disclaimer nush.

[00:09:11] Speaker 00:
I'm sorry.

[00:09:11] Speaker 03:
I didn't hear that.

[00:09:12] Speaker 03:
I don't see Gentry Gallery resting on a disclaimer nush.

[00:09:18] Speaker 00:
Well, this court has repeatedly said that in cases like Carnegie Mellon and Amgen and Cooper Cameron.

[00:09:24] Speaker 00:
It's said that.

[00:09:25] Speaker 00:
That case stands for the problem.

[00:09:27] Speaker 03:
I don't recall that that was the language that was used in Carnegie Mellon.

[00:09:34] Speaker 00:
I don't know if they use the word disclaimer.

[00:09:36] Speaker 00:
Particularly, what they say is that Gentry Gallery is a case about where the inventor makes clear that he is not claiming to have invented the full scope of the genus.

[00:09:46] Speaker 00:
I call that disclaimer as a shorthand, but that's what we're talking about here.

[00:09:49] Speaker 00:
And what the court has made clear in cases like Cooper Cameron

[00:09:52] Speaker 00:
is that that kind of finding has to be, that kind of message has to be conveyed clearly and ambiguously.

[00:09:59] Speaker 00:
Johnson, the court used the word crystal clear.

[00:10:03] Speaker 00:
And the board did not find that here.

[00:10:04] Speaker 00:
Maybe the board thinks that the inventor clearly thought that this was, what they said, was an essential element of the invention.

[00:10:14] Speaker 00:
This court has rejected the essential element test repeatedly.

[00:10:17] Speaker 00:
No, no, no, no.

[00:10:18] Speaker 00:
It's not right.

[00:10:19] Speaker 03:
It's rejected the essential element of the invention as being a requirement beyond the disclosure of the both embodiments that are being claimed.

[00:10:32] Speaker 00:
OK, but even if that's right,

[00:10:36] Speaker 00:
the cases still make clear that if you are going to find a written description error because the inventor has made clear that they are not the inventor of the full scope of the genus, that that has to be found clearly and unambiguously.

[00:10:51] Speaker 00:
And the board did not find that here because it didn't understand that that was the test.

[00:10:56] Speaker 00:
And again, it may be that on remand, the board will say, well, it was clear and unambiguous here.

[00:11:01] Speaker 00:
And we could have a very difficult substantial evidence appeal from that if we elected to take it.

[00:11:07] Speaker 00:
But again, to us, the most important point is that this court make clear that the limitation of that sort, what I've been calling a disclaimer, has to be claimed unambiguous.

[00:11:17] Speaker 00:
And that is not sufficient for Motorola or another challenger to simply identify some version of the lens assembly

[00:11:26] Speaker 00:
that isn't described in the patent, because that's always going to be possible.

[00:11:29] Speaker 00:
There are thousands of permutations of every valid lens design patent, most of which have not been described.

[00:11:38] Speaker 00:
And that's the function of the genus species line of cases is to make clear that that

[00:11:44] Speaker 00:
Mere failure to describe all the permutations is not a fatal written description error.

[00:11:49] Speaker 00:
And then you have to look beyond that.

[00:11:51] Speaker 00:
And you have to consider things like predictability of the error, which the board here did not do.

[00:11:55] Speaker 00:
If I could reserve for a moment of my time.

[00:11:56] Speaker 03:
OK, thank you.

[00:12:01] Speaker 03:
Ms.

[00:12:02] Speaker 03:
Chelsea?

[00:12:07] Speaker 04:
May I please the court?

[00:12:09] Speaker 04:
This is an ordinary written description case.

[00:12:12] Speaker 04:
The 2012 application is consistent from front to back.

[00:12:17] Speaker 04:
The abstract, the claims, the embodiments, descriptions of the present invention, and summary dimension all state that the first lens is positive and the second lens is negative.

[00:12:28] Speaker 04:
In contrast, the application is clear that for the third lens, for example, it could be either positive or negative.

[00:12:37] Speaker 04:
The application also explains reasons why the first one is positive and why the second one is negative.

[00:12:45] Speaker 04:
The extrinsic evidence here is also one-sided.

[00:12:48] Speaker 04:
Only Motorola had an expert, and the board found his testimony persuasive.

[00:12:55] Speaker 04:
That included his testimony.

[00:12:57] Speaker 04:
that the defining feature of the first lens was its positive power, and the defining feature of the second lens was its negative power.

[00:13:07] Speaker 04:
In response, Largon only has a turning argument.

[00:13:12] Speaker 03:
And most of the boards- The argument the board didn't articulate the correct standard here for a genus species situation.

[00:13:22] Speaker 03:
What's your answer to that?

[00:13:24] Speaker 04:
This is not a genus species case.

[00:13:26] Speaker 04:
There are times when an application or a specification teaches as close as a species.

[00:13:35] Speaker 04:
And there's a question about whether or not that conveys possession to a skilled artisan of a genus.

[00:13:44] Speaker 04:
But in this case, and regardless of whether the genus species analytical tool is helpful, the law of written description never changes.

[00:13:52] Speaker 04:
It's still the same law.

[00:13:54] Speaker 04:
But in this case, that genus species analytical tool

[00:13:57] Speaker 04:
isn't helpful because the specification of the 2012 application is so clear about what the inventor conveyed as it was in the scope of his invention.

[00:14:10] Speaker 01:
Did the board analyze whether this is a genus species case, and did it get it right?

[00:14:17] Speaker 04:
The board declined to apply the genus species cases here.

[00:14:21] Speaker 04:
We don't concede that the board declined to apply it for the reason Largan argues.

[00:14:28] Speaker 04:
They, in their brief, opening brief at page 22, they argue and admit that it's not clear that the reason why they argue is the reason why the board declined to apply them here.

[00:14:39] Speaker 04:
The board, in the beginning of its analysis, if you look at the appendix 22, it says that, after it says that it's not going to apply genus species cases, it says that

[00:14:51] Speaker 04:
The lens element of positive power has the opposite effect of a lens element of negative power.

[00:15:00] Speaker 04:
And if you look at this court's cases like Ariad and Bilstead that talk about when a species can disclose a genus, they talk about how the species has to be representative of the genus.

[00:15:12] Speaker 04:
or in talking about predictability, and Bill said, they say that if a skilled artisan would not readily discern that an undisclosed species would perform similarly to the disclosed species, that the art is unpredictable.

[00:15:29] Speaker 03:
Is part of what you're arguing that the 2012 application didn't disclose a genus, but only a species?

[00:15:36] Speaker 04:
Yes.

[00:15:38] Speaker 04:
Yes, it did not disclose.

[00:15:40] Speaker 04:
I mean, so you can consider

[00:15:43] Speaker 04:
The negative lens or positive lens is to be species of a larger genus if you're willing to accept that you can have opposites as members of the same genus.

[00:15:56] Speaker 04:
Often, members of a genus are something that's similar to each other.

[00:15:59] Speaker 04:
They're going to perform similarly.

[00:16:01] Speaker 03:
It's what you're saying that to invoke the genus species cases, you have to have a disclosure of a genus and then

[00:16:11] Speaker 03:
look to see whether there's a representative species disclosed.

[00:16:16] Speaker 03:
And here there was no disclosure of the genus in the first place.

[00:16:19] Speaker 04:
Yes, absolutely.

[00:16:20] Speaker 04:
As an area, there's no broadening statement at all that would suggest that this is a genus, that they considered it within the scope of, or that it was conveyed to the applicant that it would be within the scope of the application.

[00:16:32] Speaker 04:
Yes.

[00:16:34] Speaker 01:
Did the board consider the predictability of the art?

[00:16:39] Speaker 04:
Not using those words, but because they found in their genospecies analysis that a lens with positive power has the opposite effect of a lens of negative power.

[00:16:50] Speaker 04:
This court has said, and Bill said, that the art is unpredictable when a skilled artisan would not expect the species to perform similarly to each other.

[00:17:02] Speaker 04:
And because they made the finding that they'd have the opposite effect, we would submit that that's essentially the same finding, is that they wouldn't perform similarly.

[00:17:14] Speaker 04:
But it didn't use the language predictability in making that finding.

[00:17:22] Speaker 04:
So as our brief explained, we don't think that this court needs to reach the genus species issue, that the law of right description is clear, and this court has never held that

[00:17:32] Speaker 04:
the board or court needs to apply certain genus species tools whenever a patent owner argues that genus species cases apply.

[00:17:44] Speaker 04:
We cited cases such as D3 where

[00:17:47] Speaker 04:
on Arthur X, where there were arguments that there was a genus or a species, and this court didn't apply any sort of special predictability analysis or otherwise.

[00:17:57] Speaker 04:
And this court has never held.

[00:17:59] Speaker 04:
And then, of course, this court held in Hynex that there is no special rule for disclosure of a genus by a species.

[00:18:07] Speaker 01:
What's your response to what might be characterized as a policy argument?

[00:18:11] Speaker 01:
And we heard it again today.

[00:18:12] Speaker 01:
It's in the briefing that basically if we affirm, it's the death knell for lens assembly patents because challengers will always be able to find some characteristic that wasn't specifically disclosed in the specification.

[00:18:26] Speaker 04:
That argument doesn't have any weight.

[00:18:30] Speaker 04:
Here, the 24 application, if you look at it, it many times talks about how the preferably a certain feature is, a lens preferably has a certain feature, or it might have one feature or the other.

[00:18:46] Speaker 04:
here where the application is consistent about what the first lens had for its reflective polarity and the second lens for its, the first and second lens for their powers, that was what they defined the invention to be.

[00:19:04] Speaker 04:
And we aren't arguing that, you know, you have to affirmatively disclose every shape and every color and every material.

[00:19:16] Speaker 04:
parade of horribles at their brief arguments as a policy argument.

[00:19:19] Speaker 04:
It's what you define your invention to be in the application is what you disclose as your invention.

[00:19:28] Speaker 04:
All right, if there are no further questions, I'll save you very much time.

[00:19:33] Speaker 03:
Thank you.

[00:19:38] Speaker 00:
You can make a few quick points.

[00:19:39] Speaker 00:
I heard it suggested that this isn't a genus species case.

[00:19:43] Speaker 00:
That's the first time I've heard of this from Motorola on this appeal.

[00:19:47] Speaker 00:
They did not argue that this isn't a genus species case.

[00:19:50] Speaker 00:
It was suggested that this application doesn't claim a genus.

[00:19:55] Speaker 00:
I think it clearly does.

[00:19:56] Speaker 00:
It's just like Bill said.

[00:19:57] Speaker 03:
This application, the 2012 application, didn't make any disclosure of a genus, right?

[00:20:03] Speaker 00:
No, it does.

[00:20:04] Speaker 00:
It says a first and second lens, which includes first and second lenses of both sets of polarity.

[00:20:10] Speaker 00:
It's the same, for example, in NRA Global IP, where an initial application or initial claimed a certain kind of plastic.

[00:20:19] Speaker 03:
I thought the 2012 application said a first and second lens with a positive and negative.

[00:20:26] Speaker 00:
Oh, I see what you're saying.

[00:20:27] Speaker 00:
Yes, the claims did have the polarities in them.

[00:20:32] Speaker 00:
The final patent, though, has a genus.

[00:20:35] Speaker 00:
And the question here is whether that genus is adequately described by the 2012 application.

[00:20:41] Speaker 00:
Yes.

[00:20:42] Speaker 00:
And so I do think it's not true to say that the patent doesn't claim a genus.

[00:20:47] Speaker 00:
We also know that the board didn't sub... Why do you think that's the argument?

[00:20:50] Speaker 02:
The argument is that the document you're trying to use to date that doesn't claim a genus.

[00:20:56] Speaker 02:
So therefore, you can't get support of earlier priority date, because there's no written description in that earlier application for the genus.

[00:21:06] Speaker 00:
That is the argument, that with written description.

[00:21:10] Speaker 02:
I don't understand what you're talking about.

[00:21:11] Speaker 02:
I mean, every time you invent something, it's not a genus for everything like that, unless you say this is a representative sample of a genus.

[00:21:21] Speaker 02:
Let's say you have a patent.

[00:21:22] Speaker 02:
that has, you know, you say, I'm inventing a car.

[00:21:26] Speaker 02:
It has a combustion engine.

[00:21:27] Speaker 02:
It has brakes.

[00:21:29] Speaker 02:
It has a bunch of other things.

[00:21:31] Speaker 02:
And then a long come later, you say, I'm inventing a car.

[00:21:37] Speaker 02:
engine and all these other things.

[00:21:40] Speaker 02:
And the claim construction is, well, when you say engine, it includes both combustion and electric.

[00:21:46] Speaker 02:
Was that earlier thing that specifically laid out a combustion engine, a genus for all cars?

[00:21:53] Speaker 00:
Well, the question would be, in the final patent, which claims the genus of all cars, is there an adequate disclosure of the full scope of that genus

[00:22:01] Speaker 00:
in the written description that just talks about the gas cars, if I'm understanding your hypothetical correctly.

[00:22:06] Speaker 00:
Yeah.

[00:22:07] Speaker 02:
That earlier case has to have a genus in it for it to date back.

[00:22:11] Speaker 00:
Well, no.

[00:22:11] Speaker 00:
It has to adequately describe the broader genus.

[00:22:14] Speaker 00:
A genus?

[00:22:14] Speaker 00:
Yes.

[00:22:15] Speaker 02:
How does an invention that's solely directed to a car that has a combustion engine, a genus claim for cars with any type of engine?

[00:22:24] Speaker 00:
I would agree.

[00:22:25] Speaker 00:
The way I would look at it is that is a case, and that is a Gentry Gallery disclaimer case.

[00:22:29] Speaker 02:
That is a case in which... I don't see why your case isn't exactly the same thing.

[00:22:34] Speaker 02:
You invented the application that you're trying to get back to, invented lens assemblies that had specific combinations of positive and negative, and now you're trying to say that it also included the exact opposite.

[00:22:47] Speaker 02:
I think if the board were to... Is there anywhere in that application that suggests this is a genus claim and this is a representative sample of the genus?

[00:22:57] Speaker 00:
I think by virtue of the fact that it described a lens system that had the purpose of providing high-quality images for mobile cameras and described one species, which is absolutely typical of cases like Bill said, where they only described one species and then later expanded the claims to claim a genus.

[00:23:18] Speaker 00:
This court analyzed that under the genus-species framework.

[00:23:21] Speaker 00:
And if the court ultimately thinks that

[00:23:23] Speaker 00:
agrees with Motorola that the inventor here made clear that the invention was limited to the plus minus configuration.

[00:23:30] Speaker 00:
That is fine for the board to say, so long as it makes clear that that's the basis.

[00:23:35] Speaker 03:
I don't think that has to happen.

[00:23:36] Speaker 03:
I don't think the inventor has to specifically have the disclaimer that you're talking about, that my invention is limited to the positive.

[00:23:45] Speaker 00:
I take back the word disclaimer.

[00:23:46] Speaker 00:
So long as the board finds that the inventor made unambiguously clear that what was invented was narrower

[00:23:54] Speaker 00:
It was the ICE engine, not all engines.

[00:23:56] Speaker 00:
It was narrower than the scope of the genus.

[00:23:58] Speaker 00:
That's fine.

[00:23:59] Speaker 00:
But it did not make that finding.

[00:24:00] Speaker 00:
And it needs to make that the finding that it was clear and unambiguous.

[00:24:04] Speaker 00:
And it needs to apply the proper standard.

[00:24:06] Speaker 00:
We know it didn't apply the genus species cases because it said it didn't.

[00:24:10] Speaker 03:
Thank you.

[00:24:12] Speaker 03:
OK.

[00:24:12] Speaker 03:
Thank you.

[00:24:12] Speaker 03:
Thank you, counsel.

[00:24:13] Speaker 03:
The case is submitted.

[00:24:13] Speaker 03:
That concludes our session for this month.