[00:00:00] Speaker 00:
First case for argument this morning is 24-1846, Wild Seed Mobile versus Google.

[00:00:07] Speaker 00:
Mr. Alberti?

[00:00:09] Speaker 00:
All right.

[00:00:19] Speaker 03:
Good morning.

[00:00:20] Speaker 03:
May it please the court?

[00:00:22] Speaker 03:
This appeal turns on two dispositive claim construction errors.

[00:00:27] Speaker 03:
The first error made by the board affects all claims.

[00:00:30] Speaker 03:
And with respect to that error, the board interpreted the phrase taken from a message to mean things as far as a human-style takeaway, an inference, or some complex derivation.

[00:00:45] Speaker 03:
However, when read properly in the context of the 414 patent,

[00:00:49] Speaker 03:
the phrase taken from a message should have been interpreted to mean extracted from a message.

[00:00:56] Speaker 03:
That is, the information was extracted from a message that was on the cellular device.

[00:01:01] Speaker 03:
The second dispositive claim construction error affects claims 2, 3, 10, and 13.

[00:01:09] Speaker 03:
And there, the board clearly ignored the antecedent basis of the phrase the provided information

[00:01:17] Speaker 03:
which ties back to the information that was extracted from the message in claim one.

[00:01:24] Speaker 03:
When read properly in context, the prior art did not teach that and the board never addressed that issue.

[00:01:30] Speaker 00:
Well, the challenge you have in this case is that even though you've got a favorable standard of review, i.e.

[00:01:36] Speaker 00:
de novo, the board did a really thorough review.

[00:01:39] Speaker 00:
I mean, on the taken, I don't know how many pages, but it's a lot of pages.

[00:01:44] Speaker 00:
And they met every single one of your arguments, figure eight, the words and the specification, the file history.

[00:01:51] Speaker 00:
So show me the error.

[00:01:54] Speaker 00:
Show me where they really were wrong in construing it based on the spec and the arguments you made to the board.

[00:02:00] Speaker 03:
Well, it begins with the framework that they adopted.

[00:02:02] Speaker 03:
They turned the Phillips standard in reverse.

[00:02:07] Speaker 03:
They started with a generic dictionary and pointed to some definitions about taken, which could mean certainly a lot of different things.

[00:02:17] Speaker 03:
But you have to start with the patent claims

[00:02:21] Speaker 03:
in the context of the specification.

[00:02:23] Speaker 03:
So starting with the claims at Appendix 86, we'll see that Claim 1 clearly states that the information is first associated with the user of the cellular device

[00:02:36] Speaker 03:
And that information is taken by the cellular device.

[00:02:41] Speaker 03:
So we're not talking about information taken from a human user, such as maybe information that you might take from listening to a lecture or from reading a book.

[00:02:52] Speaker 00:
We're talking about... I take your point.

[00:02:55] Speaker 00:
But as you recognize, there are a lot of definitions, and some of them are broader than others.

[00:03:03] Speaker 00:
And it clearly means, and I think the board would agree, what you say it means.

[00:03:08] Speaker 00:
But that doesn't preclude it from being broader and meaning other things.

[00:03:13] Speaker 00:
And so starting from the premise that there was no disavowal here,

[00:03:17] Speaker 00:
No lexicography here.

[00:03:19] Speaker 00:
What is it in the specification that we should take away to be clear that your definition is the correct one?

[00:03:28] Speaker 03:
Well, first we have to consider the specification and what is disclosing in the context

[00:03:34] Speaker 03:
of the time of the invention.

[00:03:35] Speaker 03:
And at that time, we're talking about a cellular device, which is doing the taking here.

[00:03:41] Speaker 03:
Again, it's not a human user.

[00:03:43] Speaker 03:
And we're talking about a cellular device era 2001 and 2002.

[00:03:48] Speaker 03:
Those had rudimentary operating systems, limited processing capacity, limited memory.

[00:03:55] Speaker 03:
That was not like today's iPhone, for example.

[00:03:57] Speaker 03:
You could not run a large language model on a device like that.

[00:04:01] Speaker 01:
Is there intrinsic support for that, or is that all extrinsic evidence?

[00:04:05] Speaker 03:
There is intrinsic support specifically when it discusses the cellular device and its capabilities versus the server and its capabilities.

[00:04:16] Speaker 03:
So the server, for example, is discussed at appendix 83 and 84.

[00:04:22] Speaker 03:
from column 6, line 45, through column 7, line 34.

[00:04:28] Speaker 03:
And there, you see it's discussing a very robust system with a server operating system, mass storage, the ability to run databases.

[00:04:39] Speaker 03:
However, when the client device is explained, it's described without having any of those capabilities.

[00:04:47] Speaker 01:
Does it speak there, though,

[00:04:50] Speaker 01:
the inability to take information other than or the limited ability to take only the verbatim data that's there?

[00:05:00] Speaker 03:
Well, first, I'd like to address the verbatim issue briefly.

[00:05:06] Speaker 03:
The verbatim was a language that was really a straw man that Google introduced in its briefing.

[00:05:15] Speaker 03:
We never asked for verbatim to be the construction.

[00:05:17] Speaker 03:
We wanted the construction to be extracted, which

[00:05:20] Speaker 03:
Of course, it could involve some normalization, parsing, things of that nature.

[00:05:25] Speaker 03:
So if you take something from a message, you don't have to take the exact same thing bit for bit.

[00:05:32] Speaker 01:
I thought, though, you intended taken to be limited to you can only take something that's there.

[00:05:37] Speaker 01:
Maybe you don't have to take all of it, but you can't take something that's not there.

[00:05:41] Speaker 03:
Correct.

[00:05:41] Speaker 03:
Correct.

[00:05:42] Speaker 03:
And my point, Your Honor, was just that

[00:05:44] Speaker 03:
It could involve some normalization.

[00:05:46] Speaker 03:
It doesn't necessarily have to be a bit for bit extraction.

[00:05:50] Speaker 03:
Of course, there may be parsing, things like that.

[00:05:53] Speaker 02:
I don't understand what you mean by that.

[00:05:54] Speaker 02:
Where's the boundaries on that?

[00:05:56] Speaker 02:
Can you extrapolate from the information in the email to come up with other information that follows from that?

[00:06:05] Speaker 03:
No, that is where we draw the line.

[00:06:06] Speaker 02:
What's the difference between normalization and extrapolation?

[00:06:11] Speaker 03:
So extrapolation would be you're analyzing... Why don't you try defining normalization and explain to me what you mean by that?

[00:06:19] Speaker 03:
So, for instance, if you have a sentence that says, I like to play golf.

[00:06:26] Speaker 03:
We're not saying that the entirety of that sentence in that exact same format has to go from point A to point B, but you have to take something from that.

[00:06:35] Speaker 03:
So maybe take the word golf.

[00:06:37] Speaker 02:
So you do think it has to be verbatim.

[00:06:39] Speaker 02:
It just doesn't have to be the entirety, but it has to be verbatim from the text.

[00:06:45] Speaker 03:
You have to take something that's actually in there.

[00:06:48] Speaker 03:
Again, it doesn't have to be, say, a bit-for-bit copying.

[00:06:52] Speaker 02:
But it has to be

[00:06:54] Speaker 02:
actually in there in that word and so you don't have to copy the whole thing but what you copy you're copying exactly correct or you could copy several words they don't have to be in the exact same order you could copy you you can copy golf okay that's verbatim that's verbatim it's just not entirety of verbatim

[00:07:18] Speaker 03:
Yeah, I don't want to get into a discussion.

[00:07:21] Speaker 02:
You're the one that just got up here and started throwing around the word normalization, which if it's in the patent you can show it to me and explain what it means.

[00:07:30] Speaker 02:
But it sounded an awful lot like taking what was there and drawing inferences from it and normalizing it.

[00:07:37] Speaker 02:
And that's what you say you can't do.

[00:07:39] Speaker 02:
And you did that to rebut the notion that they created a straw man of verbatim.

[00:07:43] Speaker 02:
But it sounds an awful lot to me like you actually mean verbatim, not in its entirety, but in specific words.

[00:07:53] Speaker 03:
Again, specific words I agree with.

[00:07:55] Speaker 03:
But do they have to appear in the exact same order?

[00:07:58] Speaker 03:
That's not what we're arguing.

[00:08:00] Speaker 00:
What about the board at appendix 14 and 15 discusses the GPS example and about deciding locations and from that determining location?

[00:08:11] Speaker 00:
Talking about stuff outside that you're going through.

[00:08:14] Speaker 03:
The GPS example relates to a different module.

[00:08:17] Speaker 03:
The module that we're discussing that's related to this claim is the other sources module.

[00:08:23] Speaker 03:
And when you read the specification with respect to the other sources module and the decision block that goes along with figure 8, the way it's described is you just take that information from that module and that is added.

[00:08:38] Speaker 03:
And for example, if you look at Appendix 86, it talks about that decision block in Figure 8, says at decision block 818, when the determination is true, the process advances to block 820 where the other source information is added.

[00:08:54] Speaker 03:
So there's no inference being made, there's no analytical LLMs being run to make these complex determinations.

[00:09:02] Speaker 03:
Instead, the information is taken

[00:09:04] Speaker 03:
and it's sent to the server which does the determination and again going back to the claim language the claim language is careful to say on one hand the client device which would again at the time you're talking about a thin type device that's running

[00:09:21] Speaker 03:
limited applications.

[00:09:24] Speaker 03:
That device takes that information, it sends it to the server, and then the server, upon receiving that information, determines a proper ad.

[00:09:33] Speaker 03:
So on one hand, the claim's saying you're doing some sort of determination at the server, which could be a more complex operation, versus a simple operation, which is just taken from.

[00:09:45] Speaker 00:
Sorry, go ahead.

[00:09:47] Speaker 00:
No, I was going to give a couple of minutes on the other issues.

[00:09:50] Speaker 01:
Can I just one more on this?

[00:09:52] Speaker 01:
A-12 is where the board says there's only one sentence in the whole specification that really has anything to do with the taken question, and it doesn't help you.

[00:10:02] Speaker 01:
Is there somewhere else in the specification that you would say there is discussion as to what has to be taken?

[00:10:11] Speaker 03:
I would say, other than what I've already repeated, that you have to consider it in the context of 2001-2002.

[00:10:19] Speaker 03:
But I don't disagree with that statement.

[00:10:23] Speaker 03:
If I could get to the dependent claim issue quickly.

[00:10:26] Speaker 03:
Again, from Appendix 86, when you look at Claims 2 and 3,

[00:10:32] Speaker 03:
The claims clearly state that the provided information includes some additional specificity or added limitations.

[00:10:43] Speaker 03:
The provided information

[00:10:45] Speaker 03:
can only refer to the information that is provided in claim one.

[00:10:50] Speaker 03:
And in fact, Google, in their brief at page 60, admits that the provided information in claim one is the information that is taken from the message.

[00:11:02] Speaker 03:
So if the provided information in claim one is taken from a message, there can be no doubt

[00:11:09] Speaker 03:
that under the basic law of antecedent basis, because we're using the definite article the, the provided information in claims two and three has to be the information that was taken from a message.

[00:11:23] Speaker 03:
And if your honors don't have questions on that, I would reserve the rest of my time for rebuttal.

[00:11:36] Speaker 00:
Thank you.

[00:11:36] Speaker 00:
Yep.

[00:11:36] Speaker 00:
Mr. Curtis, good morning.

[00:11:45] Speaker 04:
Morning, Your Honors, and may it please the court.

[00:11:47] Speaker 04:
Tara Curtis on behalf of Google.

[00:11:50] Speaker 04:
With me is my colleagues Dan Bagatell and Jonathan Teitz.

[00:11:55] Speaker 04:
The board got it right when it determined that all the claims were unpatentable.

[00:12:01] Speaker 04:
Claim once information taken from a message limitation uses the ordinary meaning of taken.

[00:12:09] Speaker 04:
And Your Honor was correct that the board did a very thorough analysis and found that

[00:12:15] Speaker 04:
The taken limitation is not limited to just extracting verbatim language from a message.

[00:12:23] Speaker 04:
It includes deriving some information.

[00:12:27] Speaker 04:
For example.

[00:12:28] Speaker 00:
Your friend's answer to that is that in this context, I mean, yeah, taken can mean many things.

[00:12:33] Speaker 00:
But perhaps one of the more natural things is that it would be limited to taking something, taking one thing and putting it somewhere else.

[00:12:42] Speaker 00:
And your friend says, in this surrounding space, that's the best and the fairest meaning of taking.

[00:12:50] Speaker 04:
I disagree with that.

[00:12:54] Speaker 04:
In the context of the specification here, the information taken from a message can certainly be extracted verbatim.

[00:13:03] Speaker 04:
And it can also be derived.

[00:13:04] Speaker 04:
There's no limitation.

[00:13:06] Speaker 04:
There's no preclusion of that derivation piece of it.

[00:13:10] Speaker 04:
If you look at figure 8 in the description of it, it has that step for adding information from a module.

[00:13:21] Speaker 04:
And then it has the generating step.

[00:13:23] Speaker 04:
The figure itself, that's step 822, says generate information to send to the server.

[00:13:31] Speaker 04:
And remember, the claim language here is providing information to a server.

[00:13:37] Speaker 00:
Are there any limitations to the kind of information that can be derived?

[00:13:48] Speaker 04:
Well, certainly it has to have some basis in the message.

[00:13:52] Speaker 04:
For example, if the message said, let's play golf, you're not going to derive from that that the recipient is a bowler, for example.

[00:14:00] Speaker 04:
But there has to be certainly some connection from what can be derived from the information in the message.

[00:14:07] Speaker 04:
But it does not have to be literally taken verbatim from the message and given to the server in the exact form.

[00:14:17] Speaker 04:
some sort of inference that can occur.

[00:14:19] Speaker 02:
The claims don't... So for golf, if you have, let's go play golf, the obvious thing would be to show them, here are all the golf courses in an area that you can play golf.

[00:14:32] Speaker 02:
Would it also include ads for sporting goods stores that sell golf equipment?

[00:14:38] Speaker 04:
It could perhaps.

[00:14:39] Speaker 04:
There's no limitation in the claims or in the specification to sort of the extent of what can be derived.

[00:14:45] Speaker 04:
It just has to have some basis in

[00:14:47] Speaker 04:
the language of the message.

[00:14:48] Speaker 04:
And that would be something that's up to the designer of the system.

[00:14:52] Speaker 00:
But in your view, just picking up on Judge Fu's question about golf, if the message doesn't have the word golf in it, but the message says, tee time is at 5 PM, now I guess that could mean literally tea, or that could mean golf.

[00:15:07] Speaker 00:
But is that the kind of thing you're talking about that from that you can derive or extract that things about golf

[00:15:14] Speaker 04:
Yes, I think you could derive or extract some information from the message that says tea time at at 5 p.m.

[00:15:21] Speaker 04:
And and just to your honors are where we do about I'm having a Super Bowl party and then they send you an advertisement for beer It's certainly that did there's no Limit to to sort of what is derived and the extent of it

[00:15:37] Speaker 04:
just has to have some basis in the message but the evidence in the record we have from our expert all sorts of ranges of information that are words that are in a message and information that can be derived from it and so I don't know that we need to figure out the exact limits of it because we certainly have evidence in the record here that is well within even the most direct let's play golf you take from that that the user

[00:16:05] Speaker 04:
or the recipient could perhaps be a golfer.

[00:16:08] Speaker 04:
I wanted to speak briefly on the... Under his definition, right?

[00:16:12] Speaker 00:
Taken, as he described it, is not... You don't have to take the entire phrase.

[00:16:16] Speaker 00:
You can pick up a word.

[00:16:18] Speaker 00:
So that taking golf from, we're playing golf at 6 p.m.

[00:16:22] Speaker 00:
is exactly the way he would want to define taken, not.

[00:16:26] Speaker 00:
And you think it's broader than that.

[00:16:28] Speaker 04:
I think that's correct.

[00:16:29] Speaker 04:
Certainly, let's play golf is within

[00:16:32] Speaker 04:
the both parties I think definitions of taken from a message.

[00:16:37] Speaker 01:
Two points that your friend on the other side made.

[00:16:40] Speaker 01:
First you reference figure eight and step 822.

[00:16:45] Speaker 01:
They argue that that's after the taken step.

[00:16:49] Speaker 01:
So it's irrelevant.

[00:16:52] Speaker 01:
They're not disputing you on that because it's a step that happens later.

[00:16:55] Speaker 01:
And also they suggest that there's a methodological problem with the claim construction the board engaged in that it started with dictionaries when it shouldn't have done that.

[00:17:05] Speaker 01:
Could you address those two issues?

[00:17:07] Speaker 04:
Sure, Your Honor.

[00:17:08] Speaker 04:
On the first point on the step of

[00:17:11] Speaker 04:
Figure 8 and step 822.

[00:17:15] Speaker 04:
The claim language we're dealing with here is providing information to a server.

[00:17:20] Speaker 04:
So you have to look at the whole process of looking at the message and then what gets provided to the server.

[00:17:27] Speaker 04:
Looking at it in that appropriate context, figure 8 has the step of adding the information from the module and then it has that step 822 that says generate information to provide to the server.

[00:17:39] Speaker 04:
So that generating portion

[00:17:41] Speaker 04:
is within the process of taking information from a message to provide it to a server.

[00:17:48] Speaker 04:
If all we're worried about is that initial taking step, then the prior art does that, Your Honor.

[00:17:57] Speaker 04:
The only thing that it can possibly read from a message that says, let's play golf, is the word golf.

[00:18:03] Speaker 04:
And so if we're just looking at that very first initial look at the message element,

[00:18:09] Speaker 04:
That's well within the prior art.

[00:18:14] Speaker 04:
On the second point as to the framework that the board relied on, the board looked at the claim language, it looked at the specification, and then it used extrinsic evidence just to sort of shore up and confirm that its understanding of taken from a message from the claims and the specification aligned with

[00:18:37] Speaker 04:
the ordinary meaning of that term as would be used in normal parlance.

[00:18:41] Speaker 04:
And so it certainly didn't start with a dictionary definition and try to backfill information to get to that from the claims and the specification.

[00:18:51] Speaker 04:
I did want to briefly address the

[00:18:55] Speaker 00:
Can I ask one more question about that?

[00:18:56] Speaker 00:
In your brief, I think you allow for, even if they're right, even if their definition is the appropriate one, that you should prevail in any event.

[00:19:07] Speaker 00:
Because Kowalski, or whatever the prior art is, covers that as well.

[00:19:12] Speaker 00:
The board never dealt with that issue, right?

[00:19:15] Speaker 04:
That's correct, Your Honor.

[00:19:16] Speaker 04:
We do have an alternative argument that, even under Wildseed's definition, Kawasaki

[00:19:22] Speaker 04:
The prior art reference teaches that same extraction that wild seed would push for.

[00:19:30] Speaker 04:
The board did not reach that alternative argument because it agreed with our definition in the first instance.

[00:19:36] Speaker 04:
But it is something that was raised to the board.

[00:19:38] Speaker 00:
And was it in the petition?

[00:19:40] Speaker 00:
Did you offer the alternatives in the petition, or did this kind of claim construction get raised later on in the process?

[00:19:47] Speaker 04:
It came a little bit later on after Wildseed proposed its claim construction.

[00:19:52] Speaker 04:
It came up in our expert's deposition and in his reply declaration.

[00:19:58] Speaker 04:
So they had opportunity to address that as well in their reply at the hearing.

[00:20:05] Speaker 04:
Briefly, on the point about the

[00:20:07] Speaker 04:
whether a cell phone could do this sort of inference.

[00:20:10] Speaker 04:
We do have evidence from our expert, Dr. Hu, at Appendix 2288 where he says that a cell phone of that era could be programmed to perform the algorithms and the functions necessary to do that deriving.

[00:20:24] Speaker 04:
And so there was nothing really to rebut that.

[00:20:27] Speaker 04:
And so there is evidence in the record that a cell phone could do the exact type of simple derivation.

[00:20:35] Speaker 01:
the intrinsic evidence, the specification portions that your friend on the other side directed us to, and your extrinsic evidence?

[00:20:43] Speaker 01:
Is that what we have here, a dispute about what cell phones could do in the early 2000s?

[00:20:48] Speaker 04:
No, I don't think so, Your Honor.

[00:20:49] Speaker 04:
I think the claim language and the specification are very clear as to what's happening in the claims.

[00:20:56] Speaker 04:
And there's no issue of whether a cell phone is capable of performing that act.

[00:21:03] Speaker 04:
That would be more of a

[00:21:06] Speaker 04:
I guess, of an infringement question and less of a claim construction, which we certainly don't need to get into a battle of the experts here.

[00:21:14] Speaker 04:
If there are no further questions on claim one, I'll move on briefly to the dependent claims here.

[00:21:23] Speaker 04:
So the dependent claims have this phrase that has the additionally included information number of categories.

[00:21:36] Speaker 04:
of preferences, demographic information, things like that.

[00:21:41] Speaker 04:
That phrase is agnostic as to the source of the information.

[00:21:46] Speaker 04:
In claim one, the provided information, the information that is provided to a server is the information associated with the user.

[00:21:56] Speaker 04:
Now it says that the subsequent clause is that the

[00:22:02] Speaker 04:
Information is taken from a message, but that doesn't preclude other sources of information.

[00:22:07] Speaker 04:
It's a comprising claim.

[00:22:10] Speaker 04:
Let's remember that.

[00:22:12] Speaker 04:
And the recitation then in claim two of the provided information additionally includes, refers back to that initial clause of providing information to the server.

[00:22:32] Speaker 04:
And so it's not a subset of the information that is taken from a message.

[00:22:41] Speaker 04:
It's an addition to, and it specifically uses that addition in addition to language.

[00:22:47] Speaker 04:
And if we look at the specification, it's really the only interpretation that makes any sense.

[00:22:54] Speaker 04:
The specification has these separate modules that specifically provide the types of and the categories of information

[00:23:03] Speaker 04:
that are recited in Claim2.

[00:23:05] Speaker 04:
It has the behavior module that provides information about what's happening on the user's cell phone.

[00:23:13] Speaker 04:
It nowhere describes this very, very narrow act of deriving or taking these other categories of information specifically from a message from a user.

[00:23:27] Speaker 04:
And so we think that the only

[00:23:30] Speaker 04:
reasonable reading of this claim language that aligns with the specification is the board's.

[00:23:36] Speaker 00:
Your friend made some reference, if I'm recalling correctly, to an admission you made at page 60 of the red brief.

[00:23:44] Speaker 00:
Do you recalling what he said at the end?

[00:23:45] Speaker 04:
Yeah, I believe he was referring to the fact that the second clause, the information taken from a message, derives antecedent basis from the first clause and claim on the providing information to a user.

[00:23:57] Speaker 04:
That's correct.

[00:23:59] Speaker 04:
but that doesn't limit the information that gets provided to the server to only information taken from a message.

[00:24:08] Speaker 04:
And again, in claim two, it says the information additionally includes those other categories of information.

[00:24:15] Speaker 04:
And so nothing in the claim, even if that second phrase is referring back to the first phrase, the claim to the provided information likewise refers back to the

[00:24:28] Speaker 04:
providing information to the server.

[00:24:29] Speaker 04:
And I'll note that in claim one, the phrase is the information taken from a message.

[00:24:35] Speaker 04:
It doesn't say the provided information.

[00:24:37] Speaker 04:
Whereas in claim two, it does specifically say the provided information.

[00:24:41] Speaker 04:
And so it's not as if those two phrases must have the exact same scope, because they use different phrases.

[00:24:50] Speaker 04:
If there are no further questions, I'll ask that the court affirm the board's decision.

[00:25:11] Speaker 03:
Hey, police and court.

[00:25:12] Speaker 03:
I'd like to make a couple points on rebuttal here.

[00:25:15] Speaker 03:
First being the support for taken from meaning an extraction.

[00:25:22] Speaker 03:
And I'll note that the provisional application, which we haven't discussed today, provides the exact type of example that we're talking about where user A sends user B a message along the lines of I'm watching a TV show.

[00:25:38] Speaker 03:
or I'm listening to a good song on the radio, that message is sent and that specific information is used to tune into that TV or that radio station and that is at appendix 1087.

[00:25:55] Speaker 03:
With respect to the board's analysis, the board never considered under the proper construction of extraction and making their ruling.

[00:26:08] Speaker 03:
And when you look at Kawasaki, the record's clear that Kawasaki teaches a derivation and it does not teach taking something from a message and passing it to the server.

[00:26:20] Speaker 03:
With respect to the dependent claims, first of all, the brief at page 60 is very clear.

[00:26:27] Speaker 03:
They agree that the provided information in claim one is information taken from a message.

[00:26:37] Speaker 03:
If that is the case, and we agree wholeheartedly that that is true, that the provided information in claims two and three can only be the information that is taken

[00:26:50] Speaker 03:
from a message.

[00:26:51] Speaker 03:
And with respect to the specification, it actually does make sense when you take a look at the specification at appendix 85, column 10, it's explaining that all of these different

[00:27:08] Speaker 03:
pieces of information that you could get from a behavior module or these other modules, at the very end it says well you can also get this type of information from the other source module, which is what is taking that information from a message.

[00:27:24] Speaker 03:
So the idea that the reading of claims two and three doesn't make sense is simply untrue based on a reading of the

[00:27:33] Speaker 03:
the patent specification, and the provisional as well, which teaches extracting content from a message, such as a TV show or a radio show, and tuning into that.

[00:27:45] Speaker 03:
So with those two issues, unless your honors have any other questions, I'll rest.

[00:27:51] Speaker 00:
Thank you.

[00:27:52] Speaker 03:
Thank you.

[00:27:52] Speaker 00:
I thank both sides.

[00:27:53] Speaker 00:
The case is submitted.