[00:00:12] Speaker 04:
Next case is Secure Access versus Nintendo of America, 2015-1971.

[00:00:17] Speaker 04:
Mr. Billach, when you're ready.

[00:00:19] Speaker 04:
May it please the court.

[00:00:33] Speaker 00:
The district court below made three fundamental errors concerning the invention.

[00:00:37] Speaker 00:
The first error that it made is that it held that the TVA

[00:00:40] Speaker 00:
must be a detachable device.

[00:00:42] Speaker 00:
The second error that it made is that the TVA only provides a non-interactive link video signal.

[00:00:50] Speaker 00:
The third error that it made is that the TVA only works in analog conversion.

[00:00:57] Speaker 03:
Can I ask you, because you just focused on three things and I have a question about something you didn't mention, the

[00:01:04] Speaker 03:
what is it, the ported source interpretation, which says that the connection has to be to a video adapter or graphics accelerator card, so excluding other things like printer port.

[00:01:23] Speaker 03:
On the assumptions, since you didn't mention it and you want to get back to the other things, suppose I were to agree that the district court were wrong on that and that alone.

[00:01:36] Speaker 03:
Do you still have an un-infringement case that would warrant a remand?

[00:01:43] Speaker 03:
Do you understand the question?

[00:01:46] Speaker 00:
I do.

[00:01:48] Speaker 00:
Correct me if I'm wrong, but your honor is asking if we correct the term.

[00:01:53] Speaker 03:
Report its source, but otherwise leave all of the other claim constructions in place.

[00:01:59] Speaker 03:
Does that warrant remand?

[00:02:01] Speaker 03:
Would you agree, I know you haven't yet agreed, but would you agree that you don't have an infringement case at that point?

[00:02:10] Speaker 00:
It would certainly make our infringement case much more difficult.

[00:02:13] Speaker 00:
We would essentially be forced to argue doctrine of equivalence as to the analog conversion of aspects.

[00:02:20] Speaker 03:
But this is not something we've been presented the material with, so it's a question you either say, no, we give it up, or yes, we want the opportunity.

[00:02:30] Speaker 03:
Certainly.

[00:02:32] Speaker 00:
Yes, we would like the opportunity.

[00:02:34] Speaker 05:
Now I'm really confused, because I understand your debate with the other side about the three terms that you don't raise, even though they were arguably encompassed within the stipulation.

[00:02:43] Speaker 05:
So put aside that portion of the stipulation.

[00:02:46] Speaker 05:
You concede that

[00:02:49] Speaker 05:
seven of the terms are determinative.

[00:02:52] Speaker 05:
Isn't that what you said?

[00:02:54] Speaker 00:
That is correct.

[00:02:55] Speaker 05:
Right.

[00:02:55] Speaker 05:
So if we affirm on any one, there's no infringement, right?

[00:03:00] Speaker 00:
Well, it's very difficult in this case because these terms are interrelated.

[00:03:06] Speaker 00:
For instance, the TVA can translate a video adapter claim.

[00:03:11] Speaker 00:
That imputes other terms which were also misconstrued by the case.

[00:03:16] Speaker 00:
For instance, the TVA brings in the term video output port, but then video output port was also incorrectly construed.

[00:03:26] Speaker 00:
So the reason why we brought these particular seven all together is because they, in essence, overlap.

[00:03:35] Speaker 05:
But any one of them, even to the extent that one might bleed into the other, but if any one of them is right and they bleed into the other, there's no harm, right?

[00:03:44] Speaker 00:
That is correct.

[00:03:46] Speaker 05:
So and you didn't reserve DOE in your stipulation, right?

[00:03:51] Speaker 00:
I do not believe so.

[00:03:53] Speaker 00:
I do not know for certain if we reserve DOE.

[00:03:57] Speaker 00:
What we did reserve in the stipulation is we reserve the right to basically amend our case based on whatever happens here today.

[00:04:09] Speaker 03:
Now I think it's my turn to be confused.

[00:04:12] Speaker 03:
I thought you stipulated to one and only one thing.

[00:04:15] Speaker 03:
given all of the claim constructions, you have no infringement case.

[00:04:20] Speaker 03:
That you have not stipulated to the absence of infringement if you change any one piece of it.

[00:04:26] Speaker 00:
Well, I think logically, if you change any one piece, as Judge O'Malley outlined, if you change any one piece, yes, that would change our infringement analysis.

[00:04:38] Speaker 03:
But I thought you answered Judge O'Malley the opposite of that.

[00:04:46] Speaker 00:
If we change the term ported source, that still does not solve the problem of which we have concerning the analog conversion, and it does not solve the problem of two-way communication.

[00:05:03] Speaker 00:
So if, for instance, if this court only rules that ported source was improperly construed, that solves the issue of detachability.

[00:05:13] Speaker 00:
That solves the issue of whether or not the invention must be separate from the computer.

[00:05:19] Speaker 00:
But that does not solve the problem of the two-way communication if the translated video adapter works in two-way communication.

[00:05:28] Speaker 00:
And that also does not solve the problem of whether or not the TVA works in purely digital environments.

[00:05:36] Speaker 00:
So if there's a way to construe a ported source that would solve those problems, then

[00:05:42] Speaker 00:
Absolutely, then we'd still be able to make our infringement case if we solve the ported source term.

[00:05:50] Speaker 00:
So getting back to the three fundamental issues, when the district court ruled that it must be separate, it's the classic claim construction issue that happens often.

[00:06:03] Speaker 00:
The district court read in preferred embodiments from the patent into the claims, in so doing,

[00:06:11] Speaker 00:
in certain circumstances, it actually read in limitations from dependent claims back into the independent claims.

[00:06:18] Speaker 00:
For example, claim nine is the only independent claim that expressly provides for interfacing with the video output port, whereas claim one describes more generally looking for a ported source, as does

[00:06:41] Speaker 00:
Claim 13.

[00:06:42] Speaker 00:
So when the district court in construing the TVA term said that it must come from the video output port, the video signal must come from the video output port, that would work with Claim 9.

[00:06:55] Speaker 00:
But that doesn't work with the other independent claims, Claim 1 and 13.

[00:07:01] Speaker 03:
On the interactive or unidirectional claim construction,

[00:07:10] Speaker 03:
I think that the district court interpreted its own construction to mean that the video signals move in one direction only, not that there is no other bidirectional signaling.

[00:07:25] Speaker 03:
Is that how you read the construction?

[00:07:29] Speaker 00:
That is correct.

[00:07:31] Speaker 00:
Our concern is, you are correct in that it is pertaining to the video signal.

[00:07:38] Speaker 00:
It's very, very clear that Mr. Webber, in the prosecution history, he did disclaim video signals heading backwards.

[00:07:46] Speaker 00:
When discussing the Obata reference in the prosecution history, one analogy would be Obata was solving the problem of how do you get video signals going from terminal to terminal.

[00:07:59] Speaker 00:
Imagine terminals as the distal lens on the spokes on a wheel, communicating around the circumference.

[00:08:07] Speaker 00:
That's what OBATA teaches.

[00:08:09] Speaker 00:
What Mr. Weber is teaching is essentially communication going back from the hub, the distal ends of that same spoke.

[00:08:17] Speaker 00:
So there's no video signal communication from A to B within Weber, but there is in OBATA.

[00:08:26] Speaker 00:
And our concern with the district court's reading of OBATA is, you know, our concern is that it's going to provide for no interactivity.

[00:08:37] Speaker 00:
And we're very worried down the road for a lack of written description problem.

[00:08:44] Speaker 00:
Because as soon as you remove all interactivity within this circuit, the invention doesn't work.

[00:08:51] Speaker 00:
You need to have some sort of acknowledgment signals that go backwards coming from.

[00:08:57] Speaker 03:
But that's why I guess I asked the question.

[00:08:59] Speaker 03:
I took it that, just correct me if I'm wrong, that the way this debate was shaping up was that

[00:09:07] Speaker 03:
If you distinguish different kinds of signals in asking can there be bi-directional movement, then the disclaimer is pretty darn strong on no bi-directional video signals.

[00:09:24] Speaker 03:
It is equally clear within the specification that there can be some signals bi-directional.

[00:09:30] Speaker 03:
I think your specification referred to as handshakes or control signals that say, okay, we've got a working line now or something.

[00:09:40] Speaker 03:
But that if the claim construction is understood, as I understood it and I think you agreed, to mean what can't be bidirectional is only video signal movement, not the other stuff, then pointing to the handshaking just doesn't, isn't a ground

[00:10:01] Speaker 03:
for disagreeing with the district court's claim construction on that.

[00:10:04] Speaker 03:
I guess it doesn't preclude bidirectional handshaking and shakes hands.

[00:10:09] Speaker 00:
That is correct.

[00:10:10] Speaker 00:
And so the main bone of contention that we have with this construction is the imputation of a non-interactive link.

[00:10:19] Speaker 00:
That's what we're sort of focusing on.

[00:10:21] Speaker 00:
And I understand that it goes on to qualify that of the process video signal.

[00:10:26] Speaker 00:
But given the other errors made in that construction where the district court

[00:10:31] Speaker 00:
computed the limitation of the video output port and accessory device.

[00:10:36] Speaker 00:
We were just concerned that the district court believed that there's no interactivity whatsoever.

[00:10:45] Speaker 00:
So you are correct in that, yes, the video signal does not go backwards.

[00:10:50] Speaker 00:
That's obata.

[00:10:51] Speaker 00:
Weber clearly describes handshaking signals and interactivity and timing throughout the 309 patent.

[00:11:01] Speaker 00:
So I believe that's the proper distinction from Abbata.

[00:11:05] Speaker 00:
But our issue, again, was the notion of interactivity.

[00:11:10] Speaker 00:
But again, the biggest problem is the notion that the translated video adapter must be detached.

[00:11:19] Speaker 00:
And that's simply not the case.

[00:11:20] Speaker 06:
When you say it's the biggest problem, in your view, would that one be determinative?

[00:11:26] Speaker 00:
Yes, it would.

[00:11:28] Speaker 00:
Because you know,

[00:11:31] Speaker 00:
There's no dispute that the TVA can be added to an existing computer system.

[00:11:40] Speaker 00:
However, in column 13, lines 48 to 57 of the 309 patent, Mr. Weber makes it very, very clear that what he's patenting is a method.

[00:11:53] Speaker 00:
And he said that it can be installed on LitterArt microprocessor-based motherboard

[00:12:01] Speaker 00:
hardware.

[00:12:02] Speaker 00:
So he understood what exactly he was doing.

[00:12:05] Speaker 00:
What he was able to demonstrate in order to provide some sort of support for this method is, look, I have these components.

[00:12:13] Speaker 00:
I can assemble them in such a way that they operate functionally distinct from the main computer.

[00:12:19] Speaker 00:
But he makes it very, very clear throughout the patent and in the claims themselves that this is a method that can be used in such a way so long as it is functionally distinct

[00:12:31] Speaker 00:
from the main video processing and the main data processing of the computer.

[00:12:39] Speaker 04:
Mr. Bilkey wanted to save some rebuttal time into that period.

[00:12:44] Speaker 00:
Yes, Your Honor.

[00:12:45] Speaker 00:
Thank you.

[00:12:47] Speaker 04:
Mr. Smith.

[00:13:08] Speaker 01:
May it please the court, Stephen Smith, on behalf of the Nintendo Appellees.

[00:13:12] Speaker 01:
And Your Honor, I'd like to begin with respect to your question about which of the claim terms are dispositive before Your Honor's.

[00:13:19] Speaker 01:
I think Secure Access makes quite clear on page six of their reply brief that's, quote, Secure Access properly raised on appeal, only the seven claim terms that would be case dispositive.

[00:13:29] Speaker 05:
But your friend on the other side was arguing today that they're only case-dispositive if you consider them all together, except perhaps the TVA being a separate and distinct.

[00:13:41] Speaker 01:
I appreciate the argument, Your Honor.

[00:13:42] Speaker 01:
But in the reply brief, we believe they made clear that all seven independently were case-dispositive.

[00:13:49] Speaker 01:
So this is the first time we're hearing that.

[00:13:50] Speaker 03:
Can you show me that?

[00:13:51] Speaker 03:
I mean, I must say, I find this just

[00:13:54] Speaker 03:
Page six of the reply.

[00:13:56] Speaker 03:
Where do they say, if we're wrong about any one of these, affirm?

[00:14:01] Speaker 01:
Do they say that exact language, Your Honor?

[00:14:03] Speaker 01:
No, in substance.

[00:14:04] Speaker 01:
No, they don't.

[00:14:06] Speaker 01:
Where do they say that in substance?

[00:14:08] Speaker 01:
The top of the page where it says, secure access properly raised on appeal, only the seven claim terms that would be case-disposited.

[00:14:17] Speaker 03:
What am I looking at?

[00:14:18] Speaker 01:
This is their reply brief, Your Honor, page six.

[00:14:26] Speaker 03:
only the seven claims that would be case-dispositive.

[00:14:32] Speaker 03:
And what do you think that means?

[00:14:34] Speaker 01:
I wrote that, Your Honor, as individually, each of the claim terms that they're appealing or they believe are case-dispositive.

[00:14:39] Speaker 03:
See, I took that to mean we have something to proceed on on a remand if we win on any one of them.

[00:14:48] Speaker 01:
I appreciate that, Your Honor.

[00:14:50] Speaker 01:
We read it differently.

[00:14:52] Speaker 01:
We read it as,

[00:14:53] Speaker 01:
all seven of them independent.

[00:14:54] Speaker 03:
So this, what I would take it to be, at best, ambiguous statement.

[00:14:58] Speaker 03:
They never say anything like that in the stipulation or anywhere else.

[00:15:03] Speaker 03:
That's going to be a waiver of their right to win on, say, six of the seven if they lose on one.

[00:15:08] Speaker 01:
No, I understand that, Your Honor.

[00:15:09] Speaker 01:
I think that's one interpretation of that language.

[00:15:13] Speaker 01:
We looked at it differently.

[00:15:13] Speaker 01:
But more to the point, though, if we step back and actually look at the claim constructions with the district court went through, here we have a very

[00:15:22] Speaker 01:
fairly uncommon situation.

[00:15:24] Speaker 03:
Can you address the ported source one, which is, if I remember right, you address in footnote seven on page 26 of your red brief.

[00:15:30] Speaker 01:
Sure, Your Honor.

[00:15:31] Speaker 03:
And I don't understand that footnote, which I think is the only place you address it.

[00:15:35] Speaker 01:
The ported source, Your Honor, is a, comes right from the claim language itself of claim one.

[00:15:43] Speaker 01:
And claim one speaks specifically about

[00:15:47] Speaker 01:
processing computer program data into a ported source of display ready first process video data signal.

[00:15:55] Speaker 01:
I'm reading from column 24, A74 column.

[00:15:58] Speaker 01:
This is claim one.

[00:16:00] Speaker 01:
And clearly the specification talks about where you can get this ported source of display ready video.

[00:16:08] Speaker 01:
It's the video adapter in the graphics card, your honor.

[00:16:11] Speaker 03:
And does the specification say you can get this from those places only and from nowhere else, like the printer port?

[00:16:19] Speaker 01:
The processed ported source of display ready first process video data signal, yes, Your Honor, with respect to first process video data signal, as opposed to printer data.

[00:16:36] Speaker 01:
So the ported source here, Your Honor, is limited to the process

[00:16:40] Speaker 01:
video data signal, as opposed to where there's dependent claims that talk about the issue of printer data.

[00:16:47] Speaker 01:
And that's the distinction.

[00:16:56] Speaker 01:
And you're out of moving to the term TVA, which is one of the central disputes between the parties here today.

[00:17:05] Speaker 01:
This is a relatively uncommon situation where we have a coin term.

[00:17:10] Speaker 01:
has no plain and ordinary meaning.

[00:17:12] Speaker 01:
The inventor himself prosecuted and wrote this patent.

[00:17:17] Speaker 01:
And he left no doubt what the TVA was.

[00:17:19] Speaker 01:
And there were several components to that.

[00:17:21] Speaker 01:
First, that it was an accessory device added to an existing computer.

[00:17:26] Speaker 01:
And this is a very central point of the invention for TVA.

[00:17:30] Speaker 01:
And that is there's two embodiments that really give life and breath to TVA.

[00:17:38] Speaker 01:
That's figure 16 and 17.

[00:17:40] Speaker 01:
One's an external embodiment that is hooked up into the video output port.

[00:17:45] Speaker 01:
The other one's an internal card that slips into or fits into the expansion bus slot.

[00:17:50] Speaker 01:
And in both of those situations, they're add-ons.

[00:17:52] Speaker 01:
Why did they want it to be add-on devices?

[00:17:55] Speaker 01:
Well, the inventor wanted the TV to operate absolutely independently from any hardware configurations, for example, Apple or IBM.

[00:18:06] Speaker 01:
TVA to operate independently from any operating system constraints.

[00:18:11] Speaker 01:
And so clearly, every embodiment in the patent where they talk about TVA is a detachable device.

[00:18:19] Speaker 01:
And this isn't a situation where we're applying plain and ordinary meaning to one skill in the art.

[00:18:24] Speaker 01:
This is where the inventor himself coined the term.

[00:18:27] Speaker 01:
There's no dispute that it's a coined term.

[00:18:29] Speaker 01:
And as Your Honors Weir, my mail, and the Goldenberg case stand for the proposition that where you coin a term, we have to look to the specification to give life and full force and effect to the definition.

[00:18:43] Speaker 01:
And critically here, I think Goldenberg has a brief explanation that where it is a coined term, it is incumbent if there's a requirement on the inventor to be precise, because we can't step outside the patent

[00:18:59] Speaker 01:
and rely upon one of ordinary skill in the art, because the term doesn't exist in the art.

[00:19:06] Speaker 01:
So we have to rely on it.

[00:19:08] Speaker 03:
I've got to bring you back to what, to me, has been my focus here.

[00:19:12] Speaker 03:
So look at, I guess, column 20.

[00:19:16] Speaker 03:
Well, actually, I guess it's Claim 8.

[00:19:20] Speaker 03:
Does not Claim 8 talk expressly about accessing the TVA input port through the computer's printer data signal output port?

[00:19:31] Speaker 03:
And then what's happening there is that something that is about to be a video signal that's displayed is coming out the printer output port, right?

[00:19:41] Speaker 01:
Well, Your Honor, we look at Claim 8 as adding additional functionality to

[00:19:46] Speaker 01:
to the TVA, that you can take the TVA and the TVA could be used with printer ports and serial ports, the serial and the parallel ports.

[00:19:55] Speaker 01:
For example, if you look at claims 19 and 20, it's sort of the same thing, Your Honor, is driving at.

[00:20:01] Speaker 03:
And so you think that this piece of claim eight does not refer to a ported source, even though it is a port

[00:20:15] Speaker 03:
through which the TVA is getting the signal that it's going to display?

[00:20:22] Speaker 01:
Oh, I think I understand you now, Your Honor.

[00:20:25] Speaker 01:
This refers to accessing the TVA input port through the, that's the input port to the TVA itself.

[00:20:33] Speaker 03:
Oh, the TVA, and there's the computer, and there's got to be some connection, the input port going into the TVA.

[00:20:37] Speaker 03:
And here in claim A, it's coming out of the printer port, isn't it?

[00:20:40] Speaker 03:
Correct.

[00:20:41] Speaker 03:
Right, so how is that printer port not a ported source?

[00:20:44] Speaker 01:
Oh, I understand your point, Your Honor.

[00:20:47] Speaker 01:
It is a source of printer data.

[00:20:50] Speaker 01:
It's not a ported source of, as the claim requires, display ready first process video data signal.

[00:20:56] Speaker 01:
So it's a printer data.

[00:20:58] Speaker 01:
And if we see that in claims 19 and 20, for example, they talk about the data is ASCII or binary.

[00:21:03] Speaker 01:
It's in a different format coming out of a printer port than it is coming out of a video input port.

[00:21:08] Speaker 01:
So the distinction between, and the inventor is clear about this, there's a distinction between the different kinds of data coming through.

[00:21:13] Speaker 01:
So, Your Honor, for example, on claim eight, absolutely, you could hook the TVA up to the printer port.

[00:21:19] Speaker 01:
Absolutely, we're not making that argument that you cannot.

[00:21:22] Speaker 01:
What we're saying with respect to claim one, it talks about the display-ready, finished, processed video data, not the printer.

[00:21:30] Speaker 01:
And that's the distinction, Your Honor.

[00:21:32] Speaker 01:
So the ported source, as used in the express definition, has that requirement of being display-ready,

[00:21:40] Speaker 01:
process video data.

[00:21:41] Speaker 01:
And if we look at the specifications, it's in accord.

[00:21:45] Speaker 01:
When the inventor is talking about sources of printer data, they make clear that figures 12 and 13, for example, serial and parallel printer ports.

[00:21:55] Speaker 01:
And it's a different kind of data coming out.

[00:21:57] Speaker 01:
And therefore, different kind of hardware is necessary and different kind of functionality is necessary as well.

[00:22:07] Speaker 01:
And one other point I would like to

[00:22:09] Speaker 01:
to raise with my existing time.

[00:22:12] Speaker 01:
And this is on the port terms.

[00:22:15] Speaker 01:
The district court here, let me just step back for a moment.

[00:22:17] Speaker 01:
The district court wrote a 30-page opinion chock full of sites to the intrinsic record, reviewed every single one of the arguments that Secure made, and addressed those in detailed fashion in a well-reasoned opinion.

[00:22:30] Speaker 01:
And the issue we wanted to raise on port terms, Your Honor, is very straightforward.

[00:22:35] Speaker 01:
And that is that the term never appears

[00:22:39] Speaker 01:
in the asserted claims independently.

[00:22:42] Speaker 01:
It's always modified, whether it's TVA input port, video input port, or output port, excuse me.

[00:22:49] Speaker 01:
It never appears in isolation.

[00:22:51] Speaker 01:
What they're trying to do is to construe the term in isolation, which would be very broad and would be inappropriate given the specific claim language.

[00:23:00] Speaker 01:
And so we think that district court was right addressing this issue how they did.

[00:23:04] Speaker 01:
Their citations to the record, we believe, are absolutely correct.

[00:23:09] Speaker 01:
And therefore, we think the district court across the board on every term was accurate and did not commit error.

[00:23:15] Speaker 01:
And unless there's any more questions, Your Honor, I will cede the remaining amount of my time.

[00:23:20] Speaker 04:
Thank you, Mr. Smith.

[00:23:21] Speaker 04:
No one ever gets penalized for not using all their time.

[00:23:25] Speaker 04:
Thank you, Your Honor.

[00:23:26] Speaker 04:
I appreciate that.

[00:23:27] Speaker 04:
Mr. Billach has some rebuttal time.

[00:23:36] Speaker 00:
Thank you.

[00:23:38] Speaker 00:
To Mr. Smith's last point concerning the port terms, he's absolutely right that port is never used in isolation.

[00:23:48] Speaker 00:
But it's a bit of a cute argument to say that it's never used in isolation because he's essentially taking the surrounding language around port

[00:24:00] Speaker 00:
and trying to reconstrue port to complicate the reading of the TVA.

[00:24:07] Speaker 00:
So our position was and is, it's a fairly plain, broad reading of the term port because it is surrounded by modifying adjectives and modifying words.

[00:24:19] Speaker 00:
So port can be construed as it's known in the art, and we can just leave all the other TVA input port issues or terms alone.

[00:24:29] Speaker 00:
Now, as Judge Toronto was saying earlier concerning Claim 8, if we are to take the district court's construction on TVA as it is, that's going to read out Claim 8.

[00:24:45] Speaker 00:
That's going to ignore the fact that the TVA can accept video data from any ported source, which includes a printer port.

[00:24:57] Speaker 00:
It's not.

[00:24:58] Speaker 03:
In claim 8 and in, I guess, around column 8, lines 11 through 15, is the printer court the gateway through which processed video signals are moving or some other kind of signal, which I took it to be your friend's

[00:25:19] Speaker 03:
explanation for why the claimate really doesn't undermine the district court's claim construction, limiting the ported source to a video adapter or graphics accelerator card.

[00:25:35] Speaker 00:
You hit the issue right on the head.

[00:25:38] Speaker 00:
There's a very important distinction between the processed video signal and the processed video data signal.

[00:25:47] Speaker 00:
Process video signal is claimed in claim nine.

[00:25:51] Speaker 00:
Process video data signal is described in claim one.

[00:25:55] Speaker 00:
The process video data signal.

[00:25:56] Speaker 02:
What about claim eight?

[00:25:58] Speaker 02:
What's going on in claim eight?

[00:25:59] Speaker 02:
What signal is moving through the computer's printer port?

[00:26:07] Speaker 03:
A printer, what is the computer's printer data signal output port?

[00:26:11] Speaker 03:
What's moving through there?

[00:26:13] Speaker 00:
That, very plainly as it says right there, it's a printer data signal.

[00:26:17] Speaker 03:
And is that a type of first processed video data signal or not?

[00:26:23] Speaker 00:
Yes.

[00:26:24] Speaker 03:
How do we know that?

[00:26:25] Speaker 03:
Because... I took it again.

[00:26:26] Speaker 03:
Your friend on the opposite side was, as I'm understanding, and I could be misunderstanding it, was answering my question about Claimate by saying, different signal.

[00:26:37] Speaker 03:
So it doesn't matter that the different signal is coming out of something other than the video adapter or graphics accelerator card, because the claim construction applies only to the video, the first processed video or the processed video data signal.

[00:26:53] Speaker 00:
Well, the reason, and I believe I'm over my time if I may answer.

[00:26:57] Speaker 04:
You can answer the question now.

[00:26:59] Speaker 00:
Thank you.

[00:27:01] Speaker 00:
How we know that video data signal is sort of an umbrella term,

[00:27:07] Speaker 00:
is just simple claim differentiation.

[00:27:13] Speaker 00:
You have a broad term within claim one that describes a sort of genus of types of video data signals that come out.

[00:27:20] Speaker 00:
And then you have a subsequent species under that genus of the type of video data signal.

[00:27:25] Speaker 00:
In this case, with claim eight, it would be the printer data.

[00:27:30] Speaker 00:
And elsewhere in the patent, Mr. Weber describes taking in that printer data and then reading it out.

[00:27:37] Speaker 00:
as something that is video data that can be displayed on the secondary display.

[00:27:43] Speaker 04:
And if there are no other questions, I'd like to thank you for your time.