[00:00:30] Speaker 00:
Okay, next case is number 14, 1401, Samsung Electronics Corporation against CCP Systems AG, Mr. McCullers.

[00:00:42] Speaker 02:
Thank you, Your Honors.

[00:00:43] Speaker 02:
May it please the Court, I plan to allocate six minutes to Samsung's appeal and then reserve nine minutes of rebuttal time to respond to CCP's cross-appeal and power appeal.

[00:00:55] Speaker 02:
Your Honor's claims 55 and 63, they are obvious over the prior Art 705 patent.

[00:01:01] Speaker 02:
These claims, they recite a system that's adapted to send and receive emails in cases defined in the script.

[00:01:08] Speaker 02:
Although the Board did not contest the teaching of sending, the Board reversed the examiner on the teaching of receiving.

[00:01:15] Speaker 02:
And for the panel's reference, there's no question of combinability of the prior art or other issues.

[00:01:20] Speaker 02:
The sole issue is whether the prior art 705 patent teaches the claimed receiving.

[00:01:26] Speaker 02:
The board's decision overturning the examiner, this is reversible error.

[00:01:31] Speaker 02:
The board's analysis, it just doesn't reconcile with the examiner's literal reading of the claim language onto the prior art.

[00:01:38] Speaker 02:
Let's talk about the 705 patent and how it works.

[00:01:43] Speaker 02:
There's no dispute as to what this patent teaches.

[00:01:45] Speaker 02:
There's an archiving server.

[00:01:47] Speaker 02:
It receives emails and places them in folders.

[00:01:51] Speaker 02:
There's a script that is associated with each folder.

[00:01:55] Speaker 01:
You don't see a distinction between a system that actively takes part in triggering the receipt of an email and a system that simply sits there and reacts to receipt of an email.

[00:02:10] Speaker 02:
So, Your Honor, so yes, in this particular case, the system, the way the claim is recited is a data processing unit that's programmed to receive emails in cases defined in the script.

[00:02:23] Speaker 02:
And in this instance, we have a system where there is an email that is placed into a folder, in this case, a folder abc at ab.com as an example.

[00:02:35] Speaker 02:
In that abc directory, that email is unquestionably received.

[00:02:39] Speaker 02:
What happens is that triggers an event.

[00:02:44] Speaker 02:
When the email is placed in that folder, the triggering event is that the script goes and pulls that email and processes it.

[00:02:52] Speaker 02:
So the script is actively invoked and in the cases defined in the script, it is receiving and processing that email because it is received in that designated folder.

[00:03:05] Speaker 02:
So the script is actively pulling the email and acting upon it.

[00:03:12] Speaker 02:
And with regard to that, there are the scripts they are received and processed with respect to the particular folder.

[00:03:20] Speaker 02:
In cases defined in the script, it refers to the fact that there are scripts associated with a particular folder, abc.saveme.com.

[00:03:29] Speaker 02:
When that script is invoked, the case defined in the script is that it goes and it pulls the email from that folder that it's designated.

[00:03:39] Speaker 01:
You'll agree that the triggering of that

[00:03:41] Speaker 01:
And first of all, it's simply the receipt, right?

[00:03:45] Speaker 02:
The triggering event is pulling the email from the folder, abc.saveme.com, the abc folder in that directory.

[00:03:55] Speaker 02:
The script goes, when that email is deposited in that folder, the script goes and triggers and pulls the email from that folder and acts upon it.

[00:04:09] Speaker 02:
And that is receipt in the case associated with that script.

[00:04:18] Speaker 01:
But the script acts after receipt of email.

[00:04:23] Speaker 01:
The script itself doesn't trigger the receipt of email.

[00:04:27] Speaker 02:
The script triggers receiving the email because it is within the system, it is within

[00:04:34] Speaker 02:
the server and the script acts upon it by pulling it from the folder.

[00:04:40] Speaker 02:
So the data processing unit, the claim is a data processing unit that is further programmed to receive emails in cases defined in the script.

[00:04:51] Speaker 01:
The board essentially found that at best, sort of collects properties of emails that are already stored.

[00:05:02] Speaker 01:
And that's a factual determination that the board made.

[00:05:06] Speaker 01:
Why don't we have to give some deference to that determination?

[00:05:09] Speaker 02:
Well, the idea that the script, that it collects properties of the message, yes, but then the script parses the body of the message and it extracts all the information.

[00:05:19] Speaker 02:
The collecting of the message is still, the script is invoking that.

[00:05:24] Speaker 02:
The script is actively collecting the properties of the message when it is pulling it from the folder, from the ABC folder.

[00:05:34] Speaker 02:
The board has not given an explanation as to what that means.

[00:05:41] Speaker 02:
The board has said that it is receiving emails and cases defined in the script, but then it doesn't explain why this reference doesn't meet that.

[00:05:54] Speaker 02:
Here, the analogy would be, if I'm sending my Federal Circuit brief to the clerk's office, the fact that

[00:06:02] Speaker 02:
The panel also receives that brief, doesn't change the fact that you the panel receive it.

[00:06:08] Speaker 02:
The fact that it went to the email, went to the clerk's office first, that doesn't change the fact that you the panel actually received my brief.

[00:06:18] Speaker 02:
So what's happening here is the script is going and pulling that email from the folder and acting upon it.

[00:06:26] Speaker 02:
So it is triggering the receipt of that email.

[00:06:31] Speaker 02:
CCP's only argument is that the fact that the script is activated later after the email is first received by the archiving server, but that argument is unpersuasive because it's ignoring the fact that we have this further receipt by the script.

[00:06:49] Speaker 02:
The fact that the server receives the email first, that's irrelevant.

[00:06:53] Speaker 02:
The script does receive the email and that's all that matters.

[00:06:59] Speaker 00:
Okay.

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

[00:07:02] Speaker 00:
Mr. McCones, we'll save the rest of your time for rebuttal.

[00:07:08] Speaker 00:
Mr. Matsui.

[00:07:11] Speaker 03:
Thank you, Your Honor.

[00:07:12] Speaker 03:
May it please the Court, Brian Matsui on behalf of CCP Systems.

[00:07:16] Speaker 03:
The board should be reversed.

[00:07:17] Speaker 03:
I'd like to first focus on CCP's appeal.

[00:07:21] Speaker 03:
The board should be reversed because its decision turns on two over broad and erroneous constructions of two key terms of the 789 patent, digital print data stream and printer.

[00:07:33] Speaker 03:
Once those erroneous constructions are set aside, the board's obviousness and anticipation rejection should be reversed.

[00:07:41] Speaker 03:
The board construed print data stream to read on data streams that cannot be printed without further formatting.

[00:07:48] Speaker 03:
even under the broadest reasonable interpretation, that cannot be correct.

[00:07:53] Speaker 03:
It gives no meaning to the word print.

[00:07:55] Speaker 03:
It ignores claim language, is inconsistent with the specification, and is contrary to the very object of the invention.

[00:08:04] Speaker 01:
Your position is that the data stream must always be output to a printer?

[00:08:10] Speaker 03:
No, Your Honor.

[00:08:11] Speaker 03:
It does not always need to be output to a printer.

[00:08:14] Speaker 03:
But it needs to be formatted such that it can tell the printer what to do.

[00:08:19] Speaker 03:
It needs to be formatted so that it can control a printer.

[00:08:23] Speaker 03:
The only explanation the board gave for its overbroad construction was that the specification does not define this term.

[00:08:32] Speaker 03:
But that's not the right inquiry here.

[00:08:34] Speaker 03:
An express definition is only required if you're, is only required, is not required to give meaning to a claim term.

[00:08:43] Speaker 03:
Here the word print is in the claim term digital print data stream.

[00:08:47] Speaker 03:
The entire invention is directed to a certain type of data streams which is limited by the use of the word print.

[00:08:56] Speaker 01:
If I could just... Your friend on the other side is going to argue that you don't read print out of the term because under the board's construction it includes PDL and non-PDL format.

[00:09:11] Speaker 03:
Well, PDLs and non-PDLs can both be print data streams.

[00:09:16] Speaker 03:
For example, Samsung cites a type of print data stream that's formatted for the control of a printer that's called SCS, and that's not a PDL format.

[00:09:27] Speaker 03:
And that's actually one of the types of print data streams that the IBM reference recites.

[00:09:33] Speaker 03:
So the fact that print data streams do not need to be limited only to PDLs.

[00:09:39] Speaker 03:
But the fact of the matter is that the specification teaches at column one, line seven, that virtually all output devices which are common today use page description languages.

[00:09:53] Speaker 03:
And the specification teaches that

[00:09:56] Speaker 03:
Page description languages are of a format to control a printer.

[00:10:01] Speaker 03:
For example, at column two, line 52, it states, printing systems are still controlled by page description language, PDL, such as PCL, PostScript, and Prescribe.

[00:10:13] Speaker 03:
And the specification makes clear that when the patent is referring to a digital print data stream, it's referring to a format that is print capable, that it's able to control a printer.

[00:10:24] Speaker 03:
For example, at column two again, line 62, the specification is teaching that the inventive method can take in a print data stream that's a PDL and transform it.

[00:10:37] Speaker 03:
It says, it is therefore an object of the present invention to specify a method for the transformation of digital print data streams which is both capable of recognizing more complex page description languages whose syntax may no longer be described with the aid of simple regular expressions

[00:10:54] Speaker 03:
and also provides the preconditions that the recognized graphic objects can be transformed into the target format.

[00:11:01] Speaker 01:
So it's the format that you're concerned about?

[00:11:04] Speaker 01:
It's the format that would allow the printing, correct?

[00:11:13] Speaker 03:
Yes, all PDLs and all print data streams

[00:11:16] Speaker 03:
are in a format for a printer.

[00:11:18] Speaker 03:
And I think that if we look at the specification at column one around line 13, the specification explains that a driver will convert the objects into a PDL suitable for printer use so that the latter can be hereby controlled directly.

[00:11:39] Speaker 03:
And so when the specification and the patent are using the word print in print data stream,

[00:11:44] Speaker 03:
They're not saying it can be any sort of data stream that can be further manipulated.

[00:11:47] Speaker 03:
They're saying it's a data stream that is output from a host computer and would go to a printer and then ordinarily would be printed.

[00:11:55] Speaker 03:
Now I think it's important to take a step back and see how this is relevant to the object of the invention because the whole point of the invention is to take that print data stream that leaves the host computer and then to manipulate it further.

[00:12:08] Speaker 03:
So using some prior art printing methods,

[00:12:10] Speaker 03:
A user might sit at a computer and might have a database program and type and want to create an invoice.

[00:12:16] Speaker 03:
So he might type in the customer name, the amount of sales, things like that.

[00:12:20] Speaker 03:
That's formatted by the database program and it's sent out as a print data stream to a printer.

[00:12:26] Speaker 03:
And it will print usually on a pre-printed invoice form and hopefully the print data that goes from the

[00:12:33] Speaker 03:
host computer to the printer will align right and everything will be in the right places.

[00:12:37] Speaker 03:
What the inventive method does is it allows the user to use that same database program and use that type in the same information and hit print and send a print data stream.

[00:12:48] Speaker 03:
But then the inventive method takes over.

[00:12:50] Speaker 03:
It parses that print data stream for graphically representable objects, text and images, saves those objects in the memory and then assigns scripts to them.

[00:12:59] Speaker 03:
So what happens is, for example, the customer name would be an object and a script might be assigned to it and find out whether or not that customer owes more money, for example, or what type of form the invoice needs to be printed in.

[00:13:13] Speaker 03:
And those scripts then will format the data, will put them back into a format to control the printer and combine it into a print data stream and output to a printer.

[00:13:26] Speaker 01:
If we ultimately agree with you on claim construction,

[00:13:30] Speaker 01:
Where exactly does that leave us?

[00:13:32] Speaker 03:
Well, then the board's decision should be reversed on all the anticipation and obvious rejections.

[00:13:38] Speaker 03:
Digital print data stream was a key term with respect to the rejection.

[00:13:43] Speaker 01:
You can see, though, that even under your construction, IBM would disclose a digital print data stream, don't you?

[00:13:49] Speaker 01:
IBM discloses it.

[00:13:52] Speaker 03:
It does have a digital print data stream, but IBM does not at all parse a digital print data stream for objects.

[00:14:00] Speaker 01:
But what if we believe we have to defer to the board's conclusion that interleave shows a parser, that the list interpreter essentially parses.

[00:14:09] Speaker 03:
Well, I think that the ordinary course, if there's a new claim construction, would be to remand here because the entire analysis would have been infected by that overbroad construction.

[00:14:19] Speaker 03:
Because Interleaf no longer has a digital print data stream, because it's just a document file stream.

[00:14:25] Speaker 03:
I mean, Interleaf is a document editing program, like Microsoft Word.

[00:14:29] Speaker 03:
Once you have the correct construction, there would be no motivation and no reason to combine any of Interleaf's aspects to IBM.

[00:14:38] Speaker 03:
IBM here is just a 400-page manual for a printing subset system of an actual computer.

[00:14:43] Speaker 01:
So essentially, they would have to do a motivation to combine analysis that they never

[00:14:47] Speaker 01:
got to because they never put together these two possibilities of interleaf teaching the parsing and your claim construction.

[00:14:57] Speaker 03:
That's correct.

[00:14:57] Speaker 03:
That's one of the problems with it.

[00:14:59] Speaker 03:
But the other fact is that there is no manipulation in IBM to digital print data stream.

[00:15:07] Speaker 03:
I think that Samsung was going to point to figure 116 of IBM and that's at

[00:15:15] Speaker 01:
So you're not conceding that IBM would show a print data stream?

[00:15:21] Speaker 03:
It would show a print data stream, but only in the traditional method.

[00:15:24] Speaker 03:
So if we look at A418, there's a traditional print methodology.

[00:15:29] Speaker 03:
And there would be a print data stream in that top row that goes from the application to the printer.

[00:15:35] Speaker 03:
But there's no manipulation there.

[00:15:37] Speaker 03:
With respect to the second figure, AFP page definition

[00:15:42] Speaker 03:
form definition, there is no print data stream.

[00:15:46] Speaker 03:
It's just unformatted data.

[00:15:48] Speaker 03:
It says it right there on the figure.

[00:15:50] Speaker 03:
So the only type of manipulation that occurs there is not to a print data stream.

[00:15:56] Speaker 01:
So you're saying you would have some additional arguments that putting aside the

[00:16:05] Speaker 01:
issue of interleaves and motivation to combine that there's something else about IBM that's not fully taught.

[00:16:09] Speaker 03:
We would have a number of arguments.

[00:16:11] Speaker 03:
Yes, I mean one another example is the board relied upon the combination of IBM and interleaves print scripting process.

[00:16:20] Speaker 03:
It's not clear what print scripting is.

[00:16:22] Speaker 03:
It's not found anywhere in those references.

[00:16:25] Speaker 03:
Print scripting only probably came about because the examiner had that over-broad construction of digital print data streams such that the document file stream was a print data stream.

[00:16:35] Speaker 03:
So all that analysis would have to be redone before the board once you have the correct construction.

[00:16:43] Speaker 03:
I'd like to turn to the printer claim, if I could, before I can answer questions.

[00:16:49] Speaker 03:
Claim 20 was also rejected by the board, and the board held that a standalone computer connected to a printer practiced Claim 20.

[00:17:04] Speaker 03:
Claim 20 says, a printer characterized in that it has a system for the transformation of a digital print data stream.

[00:17:11] Speaker 03:
That claim language

[00:17:13] Speaker 03:
IronSmith makes clear that the printer actually has to have the system incorporated to it.

[00:17:18] Speaker 03:
It just can't be connected to a computer.

[00:17:21] Speaker 03:
But more importantly, that's made even more explicit by the specification because the specification says, well, to take a step back, claim 20 is directed to a printer.

[00:17:32] Speaker 03:
Claim 21 is directed to a print server that's characterized and that has a system for the transformation of a digital print data stream.

[00:17:41] Speaker 03:
Both those claims are

[00:17:43] Speaker 03:
in the specification.

[00:17:44] Speaker 03:
It says at column 8, line 24, the system, according to the invention, can also be integrated into a printer, which would be claim 20, or else a print server, which would be claim 21.

[00:17:57] Speaker 03:
So the board's construction of printer, that it could just be a computer attached to a printer, can't be correct.

[00:18:05] Speaker 03:
Unless we're just doing further questions, I'd like to save my time.

[00:18:10] Speaker 00:
Okay.

[00:18:16] Speaker ?:
Mr. McCombs.

[00:18:18] Speaker 02:
Your honors, CCP's cross appeal, it rests on this court adopting its claim construction of print data stream.

[00:18:24] Speaker 02:
But let's step back and look at how we got here.

[00:18:27] Speaker 02:
This is re-examination where CCP had the opportunity to amend its claims and CCP did so in many respects, but it did not do so with respect to this issue.

[00:18:37] Speaker 02:
Instead, CCP is now asking the court to read in limitations that it was not willing to make express in the claims.

[00:18:44] Speaker 02:
Its construction of print data stream, it has two fundamental problems.

[00:18:48] Speaker 02:
The idea here that the print stream must be in a format to control a printer before it's read in.

[00:18:54] Speaker 02:
The first and most fundamental error here is that CCP is imposing a limitation that's just not stated in the claims.

[00:19:01] Speaker 02:
The claims recite both input print streams and output print streams.

[00:19:05] Speaker 02:
The input print stream, that's not specified to be in a format for control of a printer.

[00:19:11] Speaker 02:
The output stream though is specifically recited to be in a format for control of a printer.

[00:19:17] Speaker 02:
So thus we see we have one and only one of the two print streams being formatted for control of a printer.

[00:19:24] Speaker 02:
One and only one.

[00:19:25] Speaker 01:
Aren't you really just calling them data streams and forgetting about the point that print modifies this phrase?

[00:19:35] Speaker 02:
No, Your Honor.

[00:19:37] Speaker 02:
Print is given meaning because the print stream is capable of being printed.

[00:19:42] Speaker 02:
It's capable of being transformed for printing.

[00:19:44] Speaker 02:
The output stream is formatted for control of the printer.

[00:19:48] Speaker 02:
The input stream, it's the concept here that it is printable.

[00:19:51] Speaker 02:
It doesn't include just any stream.

[00:19:53] Speaker 02:
It couldn't be, for example, a music stream or ethernet packets.

[00:19:57] Speaker 02:
It's a stream that can be transformed by the claim process for printing.

[00:20:02] Speaker 02:
A print stream is simply a data stream that is transformed and may be output to a printer.

[00:20:07] Speaker 02:
The claim language does not explicitly require more than that.

[00:20:12] Speaker 01:
I'm having a hard time because neither the board nor the examiner really explains how they got to this claim construction.

[00:20:21] Speaker 01:
You know, it's one thing to say that we give a lot of deference to the board's analysis, but the board really didn't do any analysis here.

[00:20:29] Speaker 01:
And you're substituting your analysis for the board's analysis.

[00:20:34] Speaker 02:
Your honor, I think that in the context here, that the board's analysis and the underlying examiner's analysis makes perfect sense.

[00:20:43] Speaker 02:
Because what we're looking at is, what does the claim language say?

[00:20:46] Speaker 02:
The fact that the output stream may be formatted for control of an output device, preferably a printer.

[00:20:55] Speaker 02:
The fact that there is a transformation process going on

[00:20:58] Speaker 02:
so that it can be converted for print control itself suggests that the screen that is being read in is something that is going to be printable.

[00:21:07] Speaker 02:
And I think that that analysis is correct.

[00:21:10] Speaker 02:
The idea here that the way the claim language is worded, if the patent owner wanted to make express that it needed to be in a print control format before it was read in, that could have been done easily throughout the course of this reexamination.

[00:21:24] Speaker 02:
That was raised very early on in this reexamination process.

[00:21:28] Speaker 02:
The claim doesn't require that limitation.

[00:21:32] Speaker 02:
The second fundamental error that is a problem here with this construction is that it simply just contradicts the specification.

[00:21:42] Speaker 02:
CPP's construction, it excludes two embodiments in the specification in which the input stream is an XML document or HTML.

[00:21:51] Speaker 01:
I don't understand how you justify calling those print formats.

[00:21:55] Speaker 02:
Okay, these are formats that are not already in a format for print control, but column two, if you look at the upper portion of column two, it is specifically referring to these as formats that are to be, they're input formats to be recognized and converted.

[00:22:12] Speaker 01:
Right, for the smart printer or intelligent printer to pull down and to use to update the objects once they're parsed, right?

[00:22:21] Speaker 02:
Well, the argument that XML can be used as input for a script, that's discussed in the patent, but that doesn't negate the column two teaching of XML as an input print stream.

[00:22:35] Speaker 02:
And if we go to column two at line 21, it refers specifically to this as a print data stream, which is clearly referring to XML in the prior paragraph and the fact that XML

[00:22:47] Speaker 02:
is an input that is to be recognized and converted for printing.

[00:22:51] Speaker 02:
In the context of that portion of column two, it is clear that that's the case, that it is a format that is to be converted for printing.

[00:23:04] Speaker 02:
This then brings us to the prior art references themselves, and if the board's construction is affirmed,

[00:23:12] Speaker 02:
CCP has conceded obviousness.

[00:23:14] Speaker 02:
CCP's position here is that IBM's figure 116, which is in the record at 418, that that parses unformatted input print data.

[00:23:25] Speaker 02:
In their reply brief at page 21, they're admitting that IBM has a teaching of an input print screen and parsing under the board's construction.

[00:23:38] Speaker 01:
Well, the board didn't agree that IBM showed parsing, did it?

[00:23:44] Speaker 02:
Yes, it did.

[00:23:44] Speaker 01:
At page 11 in the... I thought the board relied on interleaf for the parsing limitation.

[00:23:50] Speaker 02:
It relied on interleaf for teaching the scripts, but what was shown was that in IBM, you have an input print screen that is parsed, and then there was the combination with the use of the interleaf scripts.

[00:24:06] Speaker 02:
In IBM's figure 116, the argument was that that doesn't teach parsing of SCS, which is signature character string SCS, which is a format that is a format for print control.

[00:24:24] Speaker 02:
What was being argued by the patent owner was that in that figure, SCS was not being parsed by IBM because

[00:24:36] Speaker 02:
SDS was only input to the upper portion of that figure, and the lower portion of that figure, the argument was that that would only parse unformatted inputs, but that was not bought by the examiner.

[00:24:47] Speaker 01:
I think you're confusing the examiner and the board.

[00:24:50] Speaker 01:
The board specifically rejected IBM under 102.

[00:24:53] Speaker 02:
It rejected IBM under 102 for the purposes of scripts.

[00:24:57] Speaker 02:
It did combine the interleaved scripts with the IBM parsing.

[00:25:05] Speaker 02:
With respect to that, there was no issue of the combinability of those two references.

[00:25:12] Speaker 02:
The analogous nature of those references was made clear because they both address object-oriented publishing with scripting functionality.

[00:25:21] Speaker 02:
As well, the analogous nature of these references did not hinge on the idea of printing.

[00:25:27] Speaker 02:
It was the idea of assigning scripts to be printed, to be executed.

[00:25:35] Speaker 02:
Just to address your honor, Claim 20, with regard to Claim 20, the board correctly found that a printer having a transformation system is obvious.

[00:25:47] Speaker 02:
It's known to have a server that is directly connected by a cable to a printer.

[00:25:51] Speaker 02:
That's what the IBM reference shows.

[00:25:54] Speaker 02:
What CCP is saying is that they have a patentable claim because they're able to wrap a box around that and make it a single chassis.

[00:26:01] Speaker 02:
But this box drawing, that was properly rejected.

[00:26:05] Speaker 02:
What the purported novelty was, was the transformation method, not where you put that.

[00:26:11] Speaker 02:
And the patent recognized this in the background and saying that it was known to put control processing functionality onto a printer.

[00:26:17] Speaker 02:
That's in the patent at column one, line 17, and at column two, line 44.

[00:26:23] Speaker 02:
So in that respect, the board got that right.

[00:26:31] Speaker 00:
Thank you, Mr. McCombs.

[00:26:35] Speaker 00:
Thank you, Your Honor.

[00:26:43] Speaker 03:
First of all, we did not need to amend our claims at any point during the re-examination on this point for the claim construction because the word print is used throughout our claims.

[00:26:52] Speaker 03:
It's in the title of our patent.

[00:26:54] Speaker 03:
It's used throughout the specification.

[00:26:56] Speaker 03:
When the patent uses the word print, it's clearly limiting the data stream that it's referring to, to a print data stream.

[00:27:05] Speaker 03:
One that's capable of telling a printer what to do in a format to control a printer.

[00:27:10] Speaker 03:
Second, the references to XML and HTML are not print data streams.

[00:27:15] Speaker 03:
They are referred to at column two as other input formats.

[00:27:20] Speaker 03:
And as the patent makes clear, Judge O'Malley, as you were mentioning,

[00:27:24] Speaker 03:
Those other input formats come into play after the input print data stream has been parsed for objects and then scripts have been assigned.

[00:27:33] Speaker 03:
At that point, those other input formats can be brought in through the scripts assigned to objects and they can be transformed.

[00:27:44] Speaker 03:
And then after that, the object can be put back into a format to control printer and output as a print data stream.

[00:27:51] Speaker 03:
So XML and HTML are nowhere referred to as a print data stream.

[00:27:57] Speaker 03:
The type of data stream that's a print data stream is one that's already in the format to control a printer.

[00:28:03] Speaker 03:
And finally, just with respect to IBM, IBM does not disclose any parsing of a print data stream.

[00:28:12] Speaker 03:
The board rejected the anticipation rejection based upon IBM because it did not have the inventive method.

[00:28:20] Speaker 03:
Once there's a new claim construction, there's no way to combine interleaf and IBM.

[00:28:26] Speaker 03:
There's no parsing of a print data stream.

[00:28:28] Speaker 03:
There's no such thing as print scripting and interleaf.

[00:28:32] Speaker 03:
So the board's decision should be reversed.

[00:28:37] Speaker 00:
Okay.

[00:28:37] Speaker 00:
Thank you, Mr. Mitsui.

[00:28:39] Speaker 00:
The case is taken under submission.