[00:00:00] Speaker 05:
The first case is number 23-1983, Xerox Corporation versus SNAP, Incorporated.

[00:00:07] Speaker 05:
Mr. Quigley, when you're ready.

[00:00:11] Speaker 04:
Good morning, Your Honors, and may it please the Court, James Quigley of McCool Smith for Appellant Xerox.

[00:00:16] Speaker 04:
The Board in this case incorrectly held that the determining limitation does not require the possibility of unexpected responses when in fact the intrinsic record shows

[00:00:25] Speaker 04:
that determining limitation does require the possibility of unexpected responses.

[00:00:30] Speaker 04:
And with that proper construction of the determining limitation, the prior art... That's not in the plain language of the claim, right?

[00:00:36] Speaker 05:
The claim language has said determining whether the response matches the expected response.

[00:00:41] Speaker 04:
Correct.

[00:00:42] Speaker 05:
The language of the claim is determining whether... So you want to read and determine whether the response matches the expected response or is an unexpected response.

[00:00:51] Speaker 04:
Not quite, Your Honor.

[00:00:53] Speaker 04:
In order for the determining limitation to have meaning, the condition must either be possible to be true or false.

[00:00:59] Speaker 04:
And so if it's always true, then the determining limitation loses meaning.

[00:01:03] Speaker 04:
And then the second issue with the construction with respect to the language is that the received response should be different than the expected response, given that under Philips, different terms are presumptively going to have different meanings, where here the board held that those terms have

[00:01:19] Speaker 04:
the same meaning, essentially.

[00:01:21] Speaker 01:
Is another way to frame your argument about the possibility of unexpected responses to say that at least one response needs to be preferred over other responses?

[00:01:34] Speaker 04:
I'm not sure that that's what we have in mind.

[00:01:38] Speaker 04:
An expected response, and maybe this is where the confusion is, we have a content package that's received.

[00:01:44] Speaker 04:
And the content package has a content piece and a set of rules corresponding to the content piece.

[00:01:49] Speaker 04:
The set of rules includes a trigger condition as well as an expected response, which could be one or more.

[00:01:55] Speaker 04:
And so those expected responses are going to correspond with the content pieces.

[00:01:59] Speaker 04:
And so what should happen is when a user responds to a presented content piece, that response will be checked against the expected responses to see if it matches.

[00:02:09] Speaker 04:
And so if expected responses and received responses entirely overlap, there's no difference in the claims.

[00:02:15] Speaker 01:
Are you arguing that there needs to be some comparison to an unexpected response in memory?

[00:02:21] Speaker 01:
Or how is that being done?

[00:02:23] Speaker 04:
So an unexpected response isn't in memory.

[00:02:24] Speaker 04:
That's sort of the point.

[00:02:26] Speaker 04:
Within a content package, we can look at the table one example in the 599 patent, appendix 175 to 177.

[00:02:33] Speaker 04:
A computer can only hold so many expected responses.

[00:02:37] Speaker 04:
So in this Japanese language, embodiments

[00:02:42] Speaker 04:
There's only so many correct ways to mimic a Japanese word.

[00:02:45] Speaker 01:
So maybe I should rephrase it then.

[00:02:47] Speaker 01:
Are you arguing that you need to compare to what would be expected responses in memory?

[00:02:51] Speaker 04:
Correct.

[00:02:52] Speaker 04:
Okay.

[00:02:52] Speaker 04:
Yeah, you should compare it to what's in memory, but in order for determining whether to have meaning, it has to be possible for it to be false.

[00:02:59] Speaker 05:
What do you think's the proper construction for this?

[00:03:02] Speaker 04:
The proper construction would be determining whether the received response matches the expected response where there's a possibility of unexpected responses.

[00:03:12] Speaker 06:
How is that different than what the board said?

[00:03:15] Speaker 04:
Because the board held that there wasn't a requirement for the possibility of unexpected responses.

[00:03:19] Speaker 05:
How does that change the analysis to the prior art?

[00:03:22] Speaker 04:
Sure.

[00:03:22] Speaker 04:
So with respect to Snapp's Rosenberg reference, the board itself held

[00:03:26] Speaker 04:
that Rosenberg has four expected responses, no unexpected responses.

[00:03:30] Speaker 04:
So Rosenberg was a simple device that Snap put forth that has four buttons where a user... Yeah, but what makes a difference?

[00:03:37] Speaker 05:
If they put in one of the... If they do something that's not an unexpected response, then what happens?

[00:03:43] Speaker 04:
So that wasn't Snap's theory.

[00:03:44] Speaker 04:
Snap's theory was that... I don't care.

[00:03:46] Speaker 05:
That's a question.

[00:03:47] Speaker 05:
What happens?

[00:03:48] Speaker 04:
We don't know, because that wasn't what was put forth.

[00:03:49] Speaker 05:
What happens in yours is somebody puts in an unexpected response.

[00:03:52] Speaker 04:
There's an action incorrect, and there's an action that's taken.

[00:03:55] Speaker 04:
If you look at table one in this case.

[00:03:57] Speaker 05:
Well, how is that an unexpected response?

[00:03:58] Speaker 05:
It's a list of here's 10 expected responses, and you take this action.

[00:04:02] Speaker 05:
If you get anything else, then you take that action.

[00:04:05] Speaker 05:
That's just a different kind of unexpected response.

[00:04:09] Speaker 05:
I don't see how this, what your argument makes any difference whatsoever to the board's analysis here.

[00:04:15] Speaker 04:
Sure.

[00:04:16] Speaker 04:
So an unexpected response is not within memory.

[00:04:19] Speaker 04:
It's not stored.

[00:04:19] Speaker 04:
The system can't know every possible response.

[00:04:23] Speaker 05:
Where does it say that expected response has to be something that's specifically stored in the memory?

[00:04:28] Speaker 05:
That sounds like you're adding even more words to this pretty simple phrase.

[00:04:32] Speaker 04:
That's part of the receiving a content package limitation where the content package has a content piece and a set of rules that correspond to the content piece.

[00:04:41] Speaker 05:
If we agree with the board on this, does it get rid of the entire case?

[00:04:46] Speaker 04:
If you agree with the board on claim construction, then SNAP's prior art is invalidating, yes.

[00:04:50] Speaker 04:
There are still issues with respect to ex and meta, but yes, that's the SNAP.

[00:04:53] Speaker 06:
Well, would we even have to reach the X and meta issues if we affirm in the snap?

[00:04:59] Speaker 04:
You would not.

[00:05:00] Speaker 06:
We would not.

[00:05:01] Speaker 06:
OK.

[00:05:01] Speaker 06:
Is your construction, I know you said it to Judge Hughes, but I'm still confused.

[00:05:06] Speaker 06:
Would you be requiring two determinations under your construction?

[00:05:10] Speaker 06:
That is, the system has to determine is the response expected and then determine if the response is unexpected?

[00:05:17] Speaker 04:
No, it would just be determining whether or not the receive response matches one of the pre-programmed expected responses.

[00:05:22] Speaker 04:
And if it does, then there's an action that's performed.

[00:05:25] Speaker 04:
And if it doesn't, then there wouldn't be one.

[00:05:28] Speaker 06:
And again, then how is that different than what the board construed here, the determining requirement to be?

[00:05:36] Speaker 04:
Because, well, we can see that with the SNAP prior art reference.

[00:05:38] Speaker 04:
The SNAP prior art reference is the board

[00:05:40] Speaker 04:
acknowledged with respect to the substitute claims, envisions only expected responses.

[00:05:46] Speaker 04:
And so the board held that system that only has expected responses is still invalidated, even though there's no possibility of unexpected.

[00:05:54] Speaker 01:
So what if a user is presented with a pop-up box with a single option, like the word OK or something like that?

[00:06:00] Speaker 01:
Is the system determining if the response matches an expected response when the user clicks OK?

[00:06:08] Speaker 04:
without having the full system that seems right.

[00:06:10] Speaker 04:
I mean, there could be an OK button or a cancel button.

[00:06:12] Speaker 04:
And both of those in that system would be expected responses, because the system is obviously awaiting one of those responses.

[00:06:19] Speaker 04:
That's similar to SNAP Rosenberg, where it has four responses to a reminder.

[00:06:23] Speaker 04:
And they're each pre-programmed, and each of those is therefore expected.

[00:06:27] Speaker 04:
Similar to a multiple choice question, this is one of the issues incorrect, the board

[00:06:32] Speaker 04:
and SNAP and Meta and X equated incorrect responses with unexpected responses.

[00:06:37] Speaker 04:
A multiple choice question, no different than Rosenberg's example, where there are four options presented.

[00:06:43] Speaker 04:
An incorrect response could still be expected in that instance, because that would be one of the options that was pre-programmed in as expected.

[00:06:50] Speaker 04:
And in fact, the board agreed that that was true

[00:06:54] Speaker 04:
in an inconsistent ruling with respect to the substitute claims, which it said were substantially similar on this issue, when it held that expected responses aren't necessarily correct.

[00:07:04] Speaker 04:
his expected response.

[00:07:05] Speaker 06:
I'd like to pursue your multiple choice metaphor because I've been really confused by your position and maybe this will help.

[00:07:12] Speaker 06:
So if we can picture a final examination that has a multiple choice part and has an open-ended short answer response part, okay, so there's two parts to the exam.

[00:07:24] Speaker 06:
Under what you think is the right construction, do your claims cover both multiple choice scenarios as well as short answer scenarios?

[00:07:33] Speaker 04:
Not the multiple choice, but the short answer.

[00:07:35] Speaker 04:
It doesn't even cover the multiple choice.

[00:07:37] Speaker 04:
The multiple choice has all expected responses.

[00:07:40] Speaker 06:
So your claims are not broad enough to cover multiple choice.

[00:07:43] Speaker 04:
In a system like Rosenberg where, for instance, it would only present four possible options.

[00:07:48] Speaker 06:
And so the argument that the board erred is that the board understood your claims as broad enough to cover both multiple choice as well as open-ended short answers.

[00:07:57] Speaker 06:
That's the problem that you see.

[00:07:59] Speaker 06:
One of, yes.

[00:08:00] Speaker 06:
And so then your construction would limit your claims to something analogous to short answer, where you could write anything in that you want.

[00:08:12] Speaker 04:
Or the table one embodiment, where there's essentially an unlimited number of ways to incorrectly mimic a phrase.

[00:08:18] Speaker 06:
And where can I see the construction that you asked the board to adopt, which is presumably the one you would want us to adopt?

[00:08:27] Speaker 06:
Where can I see that written out?

[00:08:29] Speaker 04:
What we've said in the papers to the board in here is that we would just ask that it be clear that it has to be the possibility of unexpected responses as well.

[00:08:37] Speaker 01:
I think he's asking for like a JA page or something to that effect.

[00:08:41] Speaker 06:
I am, but are you acknowledging you've never put in words what the preferred construction is?

[00:08:47] Speaker 04:
I'll look when I sit down and see if I have something to point you to.

[00:08:50] Speaker 04:
Thank you.

[00:08:51] Speaker 04:
And so this construction also matters to both the X and the meta proceedings with respect to X.

[00:08:59] Speaker 04:
X put forth the palace reference.

[00:09:01] Speaker 04:
The problem with the palace reference as X relied on it is that it also relies on all enumerated expected responses.

[00:09:08] Speaker 04:
In the board, in its final written decision at appendix pages 126 to 127, the sole basis for its decision that the X palace reference was invalidating as to this determining limitation was that the palace reference had the possibility of incorrect responses.

[00:09:23] Speaker 04:
But again, incorrect responses are not necessarily unexpected responses.

[00:09:27] Speaker 04:
And so what you might hear from my friend when she stands up and she argues for X is that, well, there's this other example in palace called words filling.

[00:09:35] Speaker 04:
There's a few problems with that.

[00:09:37] Speaker 04:
First, that wasn't raised by accident petition or its reply was waived.

[00:09:42] Speaker 04:
It wasn't ruled upon by the board in its final written decision.

[00:09:46] Speaker 04:
And third,

[00:09:47] Speaker 04:
If you look at the palace reference itself, appendix page 9935, word fill-in is but one little box within one figure on one page with no explanation of what it means at all.

[00:09:58] Speaker 04:
And so it's not even clear that word fill-in would even make a difference.

[00:10:03] Speaker 04:
And with respect to Meta, the board and Meta relied upon a combination of Lamont and Wolfe, where the board and Meta both agreed that the presented content piece would be an audio or video file from Lamont.

[00:10:15] Speaker 04:
The problem is there's no prompt or there's no reason for a user to even respond to that audio or video file.

[00:10:22] Speaker 04:
And so even with the combination of Lamont and Wolf, there's no possibility of any response, much less an expected or unexpected response.

[00:10:31] Speaker 04:
So unless Your Honor has further questions.

[00:10:33] Speaker 06:
The board found that the independent and dependent claims are unpatentable, correct?

[00:10:40] Speaker 03:
Yes, Your Honor.

[00:10:41] Speaker 06:
And unless I misunderstood, your brief only addressed the independent claims?

[00:10:45] Speaker 06:
Correct, Your Honor.

[00:10:48] Speaker 06:
Are you conceding that the dependent claims are unpatentable for our purposes?

[00:10:53] Speaker 04:
Yeah, there might have been an argument in the briefing about how the dependent claims impact the construction of the independent, but not separate patentability arguments.

[00:11:01] Speaker 01:
So they rise and fall together, right, the independent and dependent claims?

[00:11:04] Speaker 06:
Well, do they rise and fall together or are you saying even if you win on the independent claims, your dependent claims are gone because you didn't appeal that.

[00:11:13] Speaker 06:
If the independent claims fall, the dependent claims fall in this particular case.

[00:11:16] Speaker 06:
If you win on the independent claims, are the dependent claims still dead or are you asking us to revive them?

[00:11:24] Speaker 04:
Those would still be alive because they all depend upon what would be live.

[00:11:27] Speaker 06:
And do you say that in your brief?

[00:11:30] Speaker 04:
I can look for a site, your honor.

[00:11:31] Speaker 04:
Okay.

[00:11:32] Speaker 06:
Thank you.

[00:11:34] Speaker 04:
Let's try and answer further questions.

[00:11:35] Speaker 04:
I'll reserve my time for rebuttal.

[00:11:43] Speaker 05:
Mr. Tchaikovsky, am I saying that right?

[00:11:45] Speaker 05:
Yes.

[00:11:47] Speaker 05:
Thank you.

[00:11:48] Speaker 05:
You're going to, you're snapped, right?

[00:11:50] Speaker 05:
So you're going to address the claim construction argument?

[00:11:52] Speaker 02:
Yes, Your Honor.

[00:11:52] Speaker 02:
I'm here to address the claim construction arguments.

[00:11:55] Speaker 02:
Do you have any questions about claim constructions?

[00:11:56] Speaker 02:
Obviously also Rosenberg by chance, and then if there are any questions regarding some of the other issues covered in terms of references or combinations, we'll be covered by co-counsel.

[00:12:05] Speaker 05:
I assume you agree that if we agree with the board on claim construction, that this resolves the case.

[00:12:11] Speaker 02:
Correct.

[00:12:11] Speaker 02:
I mean, all claims invalidated.

[00:12:12] Speaker 02:
In fact, 1 through 25, every claim in the patent be invalidated if you agree with the board, I guess.

[00:12:21] Speaker 02:
And also, if there's any questions, Your Honor, I mean, obviously for us, it's an unrecited limitation.

[00:12:27] Speaker 02:
It's a limitation.

[00:12:28] Speaker 02:
It's unrecited in the claims.

[00:12:30] Speaker 02:
These are method claims that are performed.

[00:12:32] Speaker 02:
These are not system claims with a capability.

[00:12:34] Speaker 02:
It's unrecited in the intrinsic evidence.

[00:12:36] Speaker 02:
It's not in the specification.

[00:12:38] Speaker 02:
It's not in the prosecution history.

[00:12:40] Speaker 02:
So we focus on the actual claim language here.

[00:12:42] Speaker 02:
And there's not the possibility of an unexpected response anywhere to be found.

[00:12:47] Speaker 02:
And under that construction as you said your honor of the claim should be invalidated under the Rosenberger reference and anticipated You know I found it interesting that mr. Quigley mentioned this analogy of the multiple choice questions and in fact during the

[00:13:08] Speaker 02:
one of the hearings, he brought that up, it's A2981, the multiple choice analogy, and saying in that multiple choice analogy where you have one correct response and three incorrect responses, that bat is all expected responses.

[00:13:23] Speaker 02:
That's exactly what's covered here, is all expected responses.

[00:13:25] Speaker 02:
That's similar to the Rosenberg reference.

[00:13:27] Speaker 02:
There's no need to get to the possibility of under-secting responses unless you're just trying to avoid anticipation.

[00:13:34] Speaker 02:
Frankly, if you looked at A279,

[00:13:37] Speaker 02:
When A2980, Mr. Quigley, in describing Table 1 and Table 2 of the specification, said both of those tables in the specification are all expected responses, the mimicking with respect to Table 1 and the OK with respect to Table 2.

[00:13:52] Speaker 02:
And those are all expected responses.

[00:13:55] Speaker 02:
We find it very difficult to imagine how one, can you imagine all the issues that would transpire if you insert the possibility of an unexpected response and all the other?

[00:14:07] Speaker 02:
parties that would come before you, Your Honors, if this would be adopted, it would be saying, hey, look for these additional limitations in the claims to be added.

[00:14:15] Speaker 05:
What happens in the prior art if you get something that is not written into it as an expected response?

[00:14:24] Speaker 05:
So if you have five separate responses in the program and instruction to take action, if you type in five different things,

[00:14:34] Speaker 05:
What happens if you type in nothing or yell at the computer?

[00:14:39] Speaker 05:
I mean, that's an unexpected response, but I don't understand why.

[00:14:43] Speaker 05:
I'm baffled as to why this matters, frankly, because if you don't do something that the computer's going to recognize, which sounds like an expected response, then the computer's either gonna return an error message or do nothing.

[00:14:57] Speaker 05:
What does the prior art do in that situation?

[00:15:00] Speaker 02:
Well, at least prior art, before the board in this situation, that wasn't addressed.

[00:15:06] Speaker 02:
There's no addressing of the situation of you could, frankly, look at Rosenberg and look at figure five of Rosenberg and see that there are keys below the figure where the content is displayed.

[00:15:18] Speaker 02:
But it doesn't discuss.

[00:15:19] Speaker 02:
Nowhere was it discussed before the board what would happen if someone actually touched any of those other keys.

[00:15:24] Speaker 02:
It wasn't relevant to the claims at issue because the claims at issue don't have

[00:15:27] Speaker 02:
this possibility of an unexpected response.

[00:15:30] Speaker 02:
We don't deal with the theoretical.

[00:15:32] Speaker 02:
It's just a match of expected responses, the OK that's presented.

[00:15:36] Speaker 02:
And in Rosenberg, it's the four options there.

[00:15:39] Speaker 02:
Which is actually what the claim level also does.

[00:15:41] Speaker 02:
Yes.

[00:15:42] Speaker 05:
You determine whether the received response matches the expected response.

[00:15:47] Speaker 02:
That's correct.

[00:15:47] Speaker 02:
I mean, if we dealt with possibilities of unexpected responses, as your honor questioned,

[00:15:52] Speaker 02:
I don't know how you would deal with the infinite number of potential inaccuracies, like if we took table one.

[00:15:58] Speaker 05:
Well, I assume if their program has the capability to take action in response to something that's not pre-programmed as an expected response, that's still, in some ways, expected.

[00:16:11] Speaker 05:
Because if you have a list of 10 things, take these 10 actions if you get that.

[00:16:16] Speaker 05:
If not, take this action.

[00:16:19] Speaker 05:
That still sounds to me like,

[00:16:21] Speaker 05:
matching a Receive response to an expected one.

[00:16:26] Speaker 05:
It's just an expected one of all others or something like that.

[00:16:30] Speaker 02:
That's correct If you had if the system was able to handle other responses, it's called other or unexpected Yes, then that would still be matching an unexpected response in that instance.

[00:16:43] Speaker 06:
We don't need any additional language so when they argue that the claims need to

[00:16:50] Speaker 06:
need to require the possibility of an unexpected response.

[00:16:55] Speaker 06:
You say that that's not required, that that is not part of their claims to contemplate the possibility of an unexpected response.

[00:17:05] Speaker 02:
But it's not part of the claim, correct?

[00:17:07] Speaker 06:
It's not part of their claims.

[00:17:09] Speaker 06:
That's correct.

[00:17:10] Speaker 06:
So their claims don't cover the short answer response in an exam analogy, correct?

[00:17:20] Speaker 02:
The claims don't have limitations that require covering that analogy.

[00:17:27] Speaker 02:
And then it goes to what Judge Hughes had mentioned with respect to if there's an other category.

[00:17:32] Speaker 02:
Sure, the claims might cover the matching of another category.

[00:17:35] Speaker 02:
But your specific example of claims don't cover it, no.

[00:17:38] Speaker 06:
So your prior art does not

[00:17:41] Speaker 06:
teacher disclosed that short answer, but not a problem for you, you say, because his claims don't cover that either.

[00:17:48] Speaker 02:
Yeah, that's correct.

[00:17:49] Speaker 02:
Our prior art's all expected responses.

[00:17:52] Speaker 02:
And this is why you have them coming up with this limitation of having the possibility of an unexpected response, because the prior art is only expected.

[00:18:01] Speaker 02:
That is Rosenberg, at least, the SNAP prior art is only expected responses.

[00:18:10] Speaker 05:
Do you have anything further?

[00:18:12] Speaker 02:
I do not if you have questions about any of the prior combinations of extra.

[00:18:16] Speaker 05:
I mean, your side has some argument time left, although I would suggest you limit it to the arguments he made.

[00:18:26] Speaker 05:
Mr. Morton, I think you're up next.

[00:18:28] Speaker 05:
Yes.

[00:18:40] Speaker 03:
Thank you, Your Honors.

[00:18:41] Speaker 03:
May it please the court, Philip Morton, on behalf of Meta Platforms.

[00:18:45] Speaker 03:
I won't address the claim of construction.

[00:18:47] Speaker 03:
We agree that if you adopt the board's construction, or if you adopt their construction, that if you adopt the board's construction, you don't need to address the Meta prior art.

[00:18:59] Speaker 03:
And the Meta prior art does disclose both expected and unexpected responses, which is not something that was disputed by appellant in its

[00:19:09] Speaker 03:
papers here.

[00:19:11] Speaker 03:
The one issue that they did raise with respect to the Lamont and Wolf combination, there is substantial evidence in the record supporting the combination of those two references at appendix 82 to 85.

[00:19:26] Speaker 03:
And we direct your honors to that, to support that.

[00:19:33] Speaker 03:
Are there any other questions?

[00:19:35] Speaker 01:
I have one quick housekeeping question.

[00:19:37] Speaker 01:
So you have a subset of the claims, right?

[00:19:39] Speaker 01:
We do.

[00:19:39] Speaker 01:
As opposed to SNAP has all 1 through 25?

[00:19:42] Speaker 01:
Yes.

[00:19:43] Speaker 01:
Is there anything, I assume that the reason you just did a subset is those were the ones that were asserted against your particular client?

[00:19:51] Speaker 01:
Absolutely correct, yes.

[00:19:54] Speaker 03:
Thank you.

[00:19:54] Speaker 03:
Thank you, Your Honor.

[00:20:02] Speaker 05:
Ms.

[00:20:02] Speaker 05:
McComas.

[00:20:04] Speaker 00:
Good morning.

[00:20:04] Speaker 00:
May it please the court?

[00:20:05] Speaker 00:
And ditto.

[00:20:09] Speaker 00:
We'll just stand on our briefs, unless the court has any questions.

[00:20:12] Speaker 00:
I mean, clearly.

[00:20:13] Speaker 05:
Our colleague Judge Laurie says you never get penalized for giving the court back time.

[00:20:17] Speaker 05:
I wholeheartedly concur.

[00:20:19] Speaker 05:
Thank you.

[00:20:22] Speaker 05:
Mr. Quigley, you've got about 3 and 1 half minutes.

[00:20:25] Speaker 04:
I'll make it brief, Your Honor.

[00:20:26] Speaker 04:
To the question about where in the PTAB briefing we provided an express construction.

[00:20:33] Speaker 04:
We didn't provide that express construction.

[00:20:35] Speaker 04:
We said it just must require within the determining limitation possibility.

[00:20:38] Speaker 06:
And how about to us?

[00:20:39] Speaker 06:
Do you have a construction?

[00:20:41] Speaker 04:
The same argument was made to you.

[00:20:42] Speaker 04:
No sort of quotation that I can provide you, Your Honor.

[00:20:46] Speaker 04:
With respect to Your Honor's question about

[00:20:49] Speaker 04:
What happens when the prior art encounters something other than what's on the screen or some other button is pressed or some other routine that wasn't addressed below?

[00:20:58] Speaker 04:
I don't think it would be appropriate to address that now without that developed record.

[00:21:02] Speaker 04:
If that's something that needs to be addressed, it should be the board that does that in the first instance.

[00:21:07] Speaker 04:
And then I would just say we do dispute, contrary to what my friend said, that the meta prior art discloses the possibility of unexpected responses.

[00:21:16] Speaker 04:
Because as we talk about in the briefing, it wouldn't be combined.

[00:21:20] Speaker 04:
And there are problems with the presented content piece not even being something you can respond to.

[00:21:25] Speaker 04:
Thank you, Your Honor.

[00:21:27] Speaker 04:
Thank you.

[00:21:28] Speaker 04:
The case is submitted.