[00:00:00] Speaker 04:
Okay, so the second oral argument of the day is document number 24-2078, DK Crown Holdings v. AG 18.

[00:00:12] Speaker 04:
Please go ahead.

[00:00:13] Speaker 01:
Okay, thank you, Your Honor. May it please the Court.

[00:00:16] Speaker 01:
So this case turns on a clairclair that we discovered during a reply briefing, or as we're preparing our reply brief below, where our discussion of Claim 18, which depends from Claim 17, was discovered to be in the wrong section of the petition. It was very clear.

[00:00:35] Speaker 04:
Did you ever file a motion to correct the petition?

[00:00:40] Speaker 01:
No, we did not. Just to add some color to that, there was, early in the proceeding, the board ordered us to correct the petition to add page numbers because those had been inadvertently omitted.

[00:00:54] Speaker 01:
but that was the sua sponte order from the board. When we noticed this error, we raised it ourselves in the reply brief.

[00:01:00] Speaker 02:
It was in a footnote, right?

[00:01:01] Speaker 01:
It was in a footnote of the reply brief. We said, look, it's obvious that this claim was meant – this claim depends from 17 – The ground that applies to Claim 17 includes the Bryson ground that was being – and Bryson is the disclosure we were relying on for Claim 18. So it was clear to us that that's where we meant for that section to appear.

[00:01:18] Speaker 02:
I have to say, like, I understand your position. Yeah. But I do think that I review this for abuse of discretion, right?

[00:01:30] Speaker 01:
Do you agree with that? I don't think so.

[00:01:35] Speaker 02:
Isn't it the board's reading of the petition? So in this case... And their own rules? Yeah. That the petition has to set forth the grounds upon which the petitioners were lying?

[00:01:48] Speaker 01:
Yes, and we did. And this court's jurisprudence creates two different levels of review depending on which thing is going on here. So when we're looking at what the board said is this is a new argument you're making in reply. You're changing the grounds in reply. That's how they characterized it.

[00:02:03] Speaker 02:
They don't say you can't make a new argument in reply, right?

[00:02:07] Speaker 01:
They don't say you can't make a new argument. There's rules about what replies are okay.

[00:02:10] Speaker 02:
It has to be responsive to the position taken by the partner, right?

[00:02:18] Speaker 01:
Yes, yes, that's correct. I didn't, yeah, I apologize, I didn't review the rule before I showed up here today.

[00:02:24] Speaker 02:
Yeah, yeah.

[00:02:27] Speaker 01:
There is a rule, we all know what it says. So it does permit replies in certain circumstances, and the extent of which, how far you can go with that reply is obviously sometimes disputed.

[00:02:38] Speaker 01:
This court's jurisprudence, though, creates two different standards of review depending on which which aspect of that rule we're looking at, right? Whether it's the rule or whether it's the statute that's being analyzed. And so what we're saying, if you look at like the Core Photonics case, for instance, I think that's the most relevant case that sort of sets up this dichotomy I'm talking about. The quote from, this is from Core Photonics, it's 84F4 990, this is from 1008. Our standard review of the board's application of the newness and responsiveness restriction differs. The newness restriction differs stems from the statutory mandate that the petition govern the IPR proceeding.

[00:03:13] Speaker 01:
So whether a ground relied on is new is a question of law we reviewed de novo. And then there's some citations. The responsiveness restriction is grounded in the board's regulations, which I think is what you're asking about, Judge Stoll, compliance with which we review for abuse of discretion. So the question is, which category are we in? The problem here is the board expressly said this is a newness issue. This is from A33. Petitioner improperly seeks to add a new prior reference against Claim 18. to fill a prima facie gap in the petition. They're not saying that this is inappropriate responsiveness.

[00:03:43] Speaker 01:
They're saying this is new. And in fact, admittedly, it wasn't responsive because they never raised this issue. We were the ones who noticed the problem and raised it to the board in the first instance. The newness question is reviewed de novo. And so we think this is an issue of law that you review in the first instance de novo. And here, there's no doubt that we're raising nothing new because we didn't change any of the mappings at all.

[00:04:05] Speaker 04:
All of this court... But you wouldn't say there's no doubt.

[00:04:08] Speaker 01:
Well, I understand.

[00:04:10] Speaker 04:
They argue it. Obviously, in order for the board to consider this theory of unpatentability for claim 18, it would have to do one of two things. It would either have to add Schlottman to grounds one or two, or it would have to add claim 18 to ground three.

[00:04:32] Speaker 04:
So in that sense, there's something new going on.

[00:04:36] Speaker 01:
Well, the something new is the Claire Claire on which page this discussion appeared on.

[00:04:40] Speaker 03:
Whether you intentionally did it one way or you mistakenly did it one way, it's still a new ground for Claim 18.

[00:04:51] Speaker 03:
You may have intended to include it.

[00:04:52] Speaker 01:
Correct, yes, that's right. So you didn't do it. Well, I think that's the question. This is what the clerical error issue is all about, right? Was it meant to be there?

[00:04:59] Speaker 04:
You didn't move to correct a clerical error.

[00:05:02] Speaker 01:
Yeah, so that's what we did. I think we did in the reply. That was the point of the footnote and reply.

[00:05:07] Speaker 03:
You didn't move to correct a clerical error? You think you moved in a footnote and a reply moved to correct?

[00:05:13] Speaker 01:
Yes. I mean, the answer is, I think, to your question, yes.

[00:05:16] Speaker 04:
In our footnote, what we said was... I mean, we all know what the footnote says. It's so short, we all have to memorize it. So what if we don't think that counts? Yeah. Then where does that lead?

[00:05:29] Speaker 01:
Okay, so then I would fall back to the collateral estoppel argument, because all of the factual findings necessary to find Claim 18 were already made by the Board. They found that you would combine these references. They found that when you combine those references, you invalidate Claim 17. All Claim 18 adds to that is this feature of simulated wagering, which the board already found. Bryson?

[00:05:49] Speaker 04:
When we're talking about collateral samples, we have to know if the same issue was... actually litigated, how would you define that issue? If you want to say the issue was doing non-monetary type wagering and whether Bryson teaches that, I suppose that's one way to define the issue.

[00:06:14] Speaker 04:
But it seems like what you're asking is to define same issue as being composed of multiple separate issues that were litigated and then when you smush them together we can now find a composite issue that was litigated when smushed together and I just don't know any case that we have where you can take two separate issues and combine them and say well that claim that is the composite of those two separate litigated issues can now be said to have been litigated in the first case.

[00:06:54] Speaker 04:
Is there a Is there a decision that reflects that kind of thinking?

[00:06:59] Speaker 01:
I think the closest case coming to mind is the Zizel v. UNM case, where it was a similar issue where there was a dependent claim that needed to be addressed on remand in view of findings that had been affirmed on appeal. So you did have to combine some disclosures from different claims to get to the point.

[00:07:18] Speaker 04:
That was a substitute claim, right?

[00:07:22] Speaker 01:
Like an amended claim? Yeah, correct.

[00:07:24] Speaker 04:
It's an amended substitute claim. Yes. And I believe our case law is, when it comes to substitute amended claims, the board has independent latitude to look at and consider grounds of unpatentability that aren't actually presented by the petitioner. Relying on the same prior art, but nevertheless, the board has that latitude, and of course, We don't have an amended substitute claim here. We are more confined to what you actually presented in your petition.

[00:07:58] Speaker 04:
So that's why I'm having trouble seeing why Ziesel really applies neatly to the facts of this particular case.

[00:08:05] Speaker 01:
Right. I think you're right. to identify that as procedural difference, but it didn't, it was going, I think, to the question you were asking about these combination of issues. I think that's the closest case that really addresses this portion with combination of issues. I would say, I don't think I've ever answered your question, which is what is the issue, I would say, is an issue here. I mean, it could very well be one of two things, right? Is this disclosure of Claim 18 present in Bryson or not? And the board already found that it was, right? So that's one issue that was actually litigated.

[00:08:32] Speaker 04:
Well, wait a second. The issue of Claim 18 has a lot of different claim limitations. Because of its dependency, yes. It has everything in 17, and 16, and 15, and 12.

[00:08:46] Speaker 04:
So I wouldn't go so far as to say the board found that Claim 18 is disclosed by Bryson.

[00:08:53] Speaker 01:
Correct, but they did find that all of that text that's in Claim 18, with the exception of the preamble, is present in Bryson. And the board separately found that Claim 17 and all the claims that are in that chain from which it depended were invalid in view of the combination of Slotman and Bryson. So they made all those factual findings.

[00:09:10] Speaker 01:
The only reason they didn't make this additional finding that Claim 18 is invalid is because of this procedural issue we had with the discussion of Claim 18 appearing on the wrong page of petitions. Right? So that's why we still think that collateral estoppel, I mean, this is one of the purposes of collateral estoppel, is to act in equity to prevent relitigation of these issues and to prevent what happened here. which is now the petitioner is stopped, even though the board has already made the factual findings necessary to conclude Claim 18 is invalid. And the only reason they didn't is because they said this discussion appeared on the wrong page of your petition.

[00:09:42] Speaker 01:
Again, this was an obvious error because Claim 18 depends, as you just said, Your Honor, from Claim 17, and the ground that covers Claim 17 was not that ground. So it was clearly in the wrong place on the petition. The board has previously... corrected very similar errors and didn't follow that case law here. I mean, to the extent the board's complaint was we didn't make a separate motion to correct the clerical error, they never suggested that that was what was necessary. Again, no one had raised this before us. We were the ones who identified and pointed out saying, hey, look, this was an obvious error.

[00:10:17] Speaker 01:
Please correct it. And the board didn't, and we think that was an error, and we think the standard review for that should be denoted.

[00:10:25] Speaker 04:
do you think that even if you believe that it's de novo review as to whether what you raise in the reply is a new theory do you think and let's assume the court concludes yes it is a new theory do you think then it would still be de novo review as to whether or not the board correctly or incorrectly refused to consider the new theory or do you think For that sub-question, it really would be an abuse of discretion.

[00:10:59] Speaker 01:
I think for that sub-question, as you characterized it, it would be like an Administrative Procedure Act question.

[00:11:05] Speaker 01:
And was the Board's action here arbitrary and capricious?

[00:11:09] Speaker 01:
Which we think it was, given that it has other panel decisions on almost identical facts that went the opposite way. And there's no discussion of why the Board didn't apply that law here.

[00:11:21] Speaker 01:
I'd like to reserve the remaining time if I can.

[00:11:24] UNKNOWN:
Thank you.

[00:11:29] Speaker 00:
Good afternoon, Your Honors. May it please the Court. Jonathan Teets for AG 18, joined by Patrick McKeever.

[00:11:35] Speaker 00:
I want to start with the main issue on appeal about transporting Claim 18 into Ground 3. I want to start on the standard of review question. I think it is correct.

[00:11:46] Speaker 03:
Even if we assume it's abuse of discretion, it's pretty clear that there was a mistake here, or there was a clerical mistake. Why wasn't it an abuse of discretion claim? Because this is not an instance where this is a different independent claim that kind of is similar. It's dependent of claims that are already covered by Ground 3. So it has to depend on those grounds, too. So why wouldn't we just find an abuse of discretion for the board not to allow them to correct claims?

[00:12:17] Speaker 00:
Well, at the first point, I would say the petition makes clear that it doesn't depend from those grounds because Ground 3 excludes Claim 18.

[00:12:25] Speaker 03:
Well, I understand the petition does, but the patent itself, Claim 18, depends from 17, right?

[00:12:32] Speaker 00:
Yes.

[00:12:34] Speaker 00:
But all that means is that a ground attacking Claim 18 has to make the showing of the intervening limitations.

[00:12:42] Speaker 04:
Just to follow up on Judge Hughes' questions, logic of the petition necessarily clear that to attack Claim 18 you necessarily have to attack Claims 15 through 17, and so therefore, logically speaking, Claim 18 is part of the Dreyfus-Schlafen grounds.

[00:13:08] Speaker 00:
The only basis to make that reading is dependence.

[00:13:12] Speaker 04:
Given that the petition is clearly trying to challenge Claim 18...

[00:13:16] Speaker 00:
Right. I think dependency is the only thing in the petition that would get us there. And if I can't really make any other point than this, that question was at issue in Apple v. MPH, about whether dependency can rescue a ground that is missing a reference. And SAS doesn't let that happen. It might be different if there was actually a reference to the specific arguments that had been made, such that there was some ambiguity in the petition. But these things were presented separately.

[00:13:45] Speaker 00:
The exact same thing happened in the Apple versus MPH case we cite. Now, I want to respond to a distinction.

[00:13:52] Speaker 03:
So in the body of the argument, they'd refer to 18 underground 3, but they hadn't actually listed it underground 3. Then we might have some ambiguity to look at and see that they clearly meant to discuss 18 underground 3, even if it wasn't included in the chart. Okay.

[00:14:09] Speaker 00:
I think there are cases in which there could be a petition that had a situation like that, yes. But there's no indicia like that in this case. It's just logic, right?

[00:14:18] Speaker 03:
I mean, you have to use Bryson and Schlottman together to get all the elements of Claim 17, right? Yeah.

[00:14:30] Speaker 00:
No, because there could have been a way to try and find and argue those elements in the way – Right now, the way they did it, though.

[00:14:36] Speaker 03:
Right. The board invalidated 17 based upon a combination of Bryson and Schlottman.

[00:14:42] Speaker 03:
Correct. So 18, which depends from that, also would have had to have a combination of Bryson and Schlottman. There's no way to argue – I mean, they could have argued it – It's very hard to figure out if that's the way they have to show all the elements that they could have logically just used Bryson alone. Because otherwise, if they could have done that, they could have argued 17 as Bryson alone too, but they didn't.

[00:15:08] Speaker 00:
Right, and that may have been the error. Or it could have been a mistake in drafting the petition and misread 17 as 12.

[00:15:15] Speaker 00:
There's a variety of different mistakes that could have happened, and it's not unambiguous what happened here.

[00:15:20] Speaker 03:
Is that why it's not an abuse of discretion?

[00:15:23] Speaker 00:
I think that's a reason it's abuse of discretion. I think putting a footnote that doesn't have any reasoning in it is another reason it's abuse of discretion. And then switching grounds on appeals to say, oh, we said this was a clerical error when that wasn't.

[00:15:36] Speaker 03:
If you made a formal motion laying all this out and the board had looked at it and said, you're right, but we're not going to let you do it anyway, then it might be an abuse of discretion.

[00:15:45] Speaker 00:
I think we would be in a much harder spot there because then you, if you have a motion to correct the petition, you're at least circumventing the SAS problem because you have a new petition. And so the proceeding goes from there. And then you would have reasoning and you would have had that made that argument to the board and maybe cited prior cases.

[00:16:02] Speaker 02:
What is your argument? I think you were about to go into why you thought it was an abuse of discretion, why an abuse of discretion standard would apply. Did you have more to add on that? Because I'm particularly interested in that question.

[00:16:13] Speaker 00:
Yeah, so what I would say is there is a surface tension between Core Photonics and the other cases on this issue about de novo versus not. And one way to reconcile those cases is that the board's reliance, which is what Core Photonics says, on a ground, not in a petition, that is unlawful because that exceeds the boundary of the proceeding under the SAS doctrine through the statute.

[00:16:39] Speaker 00:
But there's no statutory prohibition on evaluating a petitioner's argument and saying, we don't see it there, and evaluating the adequacy and comparing two documents. That's fundamentally a tribunal-level judicial function.

[00:16:55] Speaker 02:
I'm giving them some discretion to figure out whether a petition is presenting something new or not.

[00:17:01] Speaker 00:
Yes, exactly.

[00:17:02] Speaker 04:
Why isn't it, I don't know, like petition construction? You know, in the sense that we're trying to figure out the boundaries, the meets and bounds of this petition. And, you know, the board made a call, and now we have to review that call. Was this theory, in fact, a new theory or not, based on the contents of the petitions?

[00:17:27] Speaker 04:
That could be developed, maybe. And then the next step would be, well, then the board's choice to entertain an arguably new theory or refusal to consider an arguably new theory. Maybe that's the abuse of discretion.

[00:17:49] Speaker 00:
I think it could involve a question of law if there is some legal question. I think a good example of that is an analogous art question and whether addressing an analogous art in a reply creates a new ground. That's a fundamentally legal question. But if it's a petition construction, as it were, that's different from claim construction because that is a discretionary call for the board. And so where it's not unreasonable. And here, the fact that I think...

[00:18:15] Speaker 00:
The footnote at Appendix 830 says this was in Grounds 1 and 2 in the petition, and then the institution decision had said Grounds 1 and 2 are anticipation and obviousness, Claim 18.

[00:18:29] Speaker 00:
Everyone was proceeding this entire time under that understanding, and so I think that's another reason that the board's understanding here was completely reasonable.

[00:18:39] Speaker 00:
I want to hop back to Apple real quick because there is a... That's the non-presidential case, right? Yes, but it is a good one. Good for you. The law is.

[00:18:53] Speaker 00:
So there are two distinctions of this case in the reply brief.

[00:18:59] Speaker 00:
One of them is that that dependency issue would have created a ground with an additional reference in it, and so it's not like this case. That distinction applies only to one of the dependent claims that was at issue there. The other two dependent claims that had this problem presented the exact same situation. where the parent ground or the parent claim had this extra prior art reference in it, and the dependent claim didn't. That's the exact same situation as here.

[00:19:31] Speaker 00:
And then the other distinction that DraftKings makes of Apple is that the petitioner there didn't ask to correct a clerical error, and I think the answer to that is the petitioner there asked for the same thing here.

[00:19:45] Speaker 00:
in that neither petitioner asked for a clerical error. They just said, because of dependency, this should be considered in the other claim. And SAS, relying on Phillips' case in this court, decided that.

[00:20:00] Speaker 00:
I want to touch on the responsiveness point also that Judge Stoll mentioned.

[00:20:06] Speaker 00:
Because I don't think there's any reasonable dispute that the footnote wasn't responsive, which would be an independent barrier to considering it.

[00:20:14] Speaker 00:
DraftKings does, in its reply brief, cite Appendix 760 and 767 and say, well, this footnote was responsive to that.

[00:20:23] Speaker 00:
But those two pages of the Patinona response are about why the limitations of 18A and 18B, this is the non-monetary compensation limitations, were not there. It wasn't an argument that things beyond that were not in that ground. And so that wouldn't be a properly responsive argument.

[00:20:49] Speaker 00:
I want to turn to the collateral estoppel issue as well.

[00:20:53] Speaker 04:
The board knocked out many claims of this patent, right?

[00:20:58] Speaker 00:
Yes.

[00:20:59] Speaker 04:
You didn't appeal that.

[00:21:01] Speaker 00:
That is correct. We chose to focus on defending the one claim in order to narrow the issues on the claimant survived.

[00:21:09] Speaker 00:
Many of the claims that were knocked out are not surrogate claims also. And so this goes to the Oren Technologies case that we cite, and that applies principles from their statement about equitable exceptions to estoppel. And one of those principles is if you don't have an adequate reason to appeal a claim because you have another claim from that same patent that provides protection on a subject matter, There's actual reasons not to apply estoppel. Another reason is that it's just weird to do it here because this is all-in-one proceeding, and we are still defending the validity of a claim.

[00:21:43] Speaker 00:
And where we defended the validity of that claim is where the action was on the non-monetary limitations of Claim 18 anyway. And so the idea that those arguments were fully fleshed out and there was actual... That non-monetary wagering limitation was in Claim 10, right? Yes.

[00:22:02] Speaker 04:
And...

[00:22:04] Speaker 04:
the petitioner had the affirmative burden to prove that Bryson taught that particular limitation.

[00:22:11] Speaker 04:
And the board found that it had met its burden, right?

[00:22:15] Speaker 00:
That is correct. And what the board said at Appendix 81 and 82, and I think this is important, the board said, based on the unopposed contentions as to limitations, we accept those as our own and then cited... the petitioner's response as to claims 1 and 10.

[00:22:32] Speaker 04:
I'm just wondering, regardless of whether you opposed it, you were there, you had the opportunity, you had the full opportunity to litigate it, and it wasn't just something that you could concede away because the petitioner still had to make its case to prove it, and the board found that it hadn't had its burden to prove it, that in fact Bryson does teach this limitation.

[00:22:58] Speaker 00:
I think what the board found was that the uncontested arguments by DraftKings on that were enough to have found that limitation met. It didn't find that in view of the arguments we made on claim 18, that limitation would have been met. And so the full and fair opportunity pronged the stop. I mean, this isn't like this issue came up five years ago. It's in this very appeal.

[00:23:24] Speaker 00:
And we happened to not respond on Claim 10 on that particular issue, but we did respond, and we responded a lot on Claim 18. And so a full and fair opportunity in actual litigation, both those prongs of collateral estoppel, that would entitle us to getting an answer on which arguments were accepted, which weren't, and why.

[00:23:46] Speaker 00:
An even easier, I think, question on forfeiture is, or on estoppel as forfeiture.

[00:23:52] Speaker 00:
Elements of collateral estoppel were not addressed in the blue brief, and I don't think have still been addressed in the gray brief, including the full and fair opportunity prong of collateral estoppel.

[00:24:06] Speaker 04:
Well, what if we assume that they fairly raised the collateral estoppel argument and we put to the side your actually litigated argument.

[00:24:20] Speaker 04:
Do you have anything else?

[00:24:22] Speaker 00:
Yeah, there's the identical issue requirement, and even if we accept... That's the thing I was discussing earlier, right? As a policy matter, that, I think, creates an appellate nightmare because now there's an invitation to go cobble together a whole bunch of different fact findings from what's appealed and not appealed. And in an IPR campaign, you end up getting notices of appeal on everything because we don't know what's going to be argued in this brief or that brief. And so it really disincentivizes focusing litigation.

[00:24:55] Speaker 00:
But even if that were the case, even if we accepted the cobbled-together theory of identical issues, the reasonable expectation of success as to the particular combination of Claim 18 hasn't been argued, and we haven't had a response on that.

[00:25:17] Speaker 00:
The other thing I want to finally address, because it was mentioned that the request to correct the petition was sua sponte from the board and that the board didn't allow other changes.

[00:25:28] Speaker 00:
No one asked for other changes to the petition. The parties could have looked. They looked at the petition reply for clerical errors, didn't, and saw some there and asked the board. And the board, in its order at Appendix 470, gave an option for additional corrections if they were deemed necessary.

[00:25:49] Speaker 00:
So for that reason, you would ask that the court affirm it.

[00:26:04] Speaker 01:
Let me start with collateral estoppel. So it's true we didn't. So first of all, we did raise it in our public brief. It's on page 25 is where that discussion began. Sentences on these facts, the court should find claim 18 unpatentable as a matter of collateral estoppel. And we cite the case law and talk about why that is here.

[00:26:22] Speaker 01:
So it hasn't been forfeited. We couldn't raise it to the board because collateral estoppel from P-TECH proceedings, of course, doesn't kick in until either the appeal is over or the patent owner decides not to appeal, which is what happened here. So in our view, this court actually has jurisdiction to apply collateral estoppel and invalidate Claim 18 as a matter of law on the record we already have. No further remand would be necessary.

[00:26:44] Speaker 01:
With respect to the Apple case, I would just say that's obviously quite distinguishable, given that in that case, Apple had to... Where's your collateral stock of argument in the blueprint?

[00:26:56] UNKNOWN:
25?

[00:26:56] Speaker 01:
25? Okay. Again, the first little paragraph on page 25 is where it begins. Okay.

[00:27:10] Speaker 01:
The Apple case involved the need to add a new motivation to combine these references. We don't have that here. Again, literally the only thing that's changing is removing the discussion of Claim 18 from one page to another in the petition. No change is necessary to the motivation to combine. No change is necessary to the mapping. It's all the same mapping. It's all the same motivation to combine that the board already found. We had proven by preponderance of the evidence. So literally there's nothing left to decide. The only question is, Should the board have gone and reached the logical conclusion that claim 18 is invalid?

[00:27:41] Speaker 01:
And our answer is yes. And, you know, to be fair, it was an error. I mean, there's no doubt. We put it in the wrong place in the petition. I fess up to that. I missed it. Everyone on my side missed it. Pat Hunter missed it in their preliminary response. The board didn't notice it in the decision. They didn't notice it. Pat Hunter missed it. Well, they didn't raise it in their preliminary response. They never raised this issue at all. It's a fair point, Your Honor. You're right. You're right. They could have been hiding. You're right. They could have been hiding this issue.

[00:28:04] Speaker 02:
It's not to their, you know, it's not their burden.

[00:28:07] Speaker 01:
No, it wasn't. You're right. I'm sorry. But they never raised it, I guess I should say. I know they never raised it. The board didn't address it in the institution decision. So, I mean, yeah, it did escape review for a while. I can see that. But once you see it, it jumps off the page at you. This was obviously meant to be in ground three. Yeah.

[00:28:25] Speaker 01:
I don't know if there's any other issues that the court wanted me to engage with.

[00:28:30] Speaker 04:
I think that's it. Thank you very much.