[00:00:57] Speaker 04: We will hear argument next in number sixteen one nine nine four skill survey against check stir Whenever you're ready, mr. Pettus [00:01:23] Speaker 03: May it please the court, my name is Richard Pettis, and I have the privilege today to represent the Appellant and Patentees Skill Survey in this appeal. [00:01:32] Speaker 03: I'd like to begin by first thanking this court for giving us an opportunity to correct what we believe is a wrongly decided decision and also a premature dismissal of the cause of action. [00:01:46] Speaker 03: As this court, I'm sure, is aware, the district court actually held in its opinion that the claimed invention was a novel ordered combination and provided new and useful results when it was applied. [00:02:06] Speaker 03: That is a holding that should have fit squarely within the Alice, McRoe, and Bascom decisions [00:02:16] Speaker 03: that have held that an unconventional arrangement when applied in a way that produces new and useful results is patent eligible. [00:02:27] Speaker 03: However, the court did not hold that way. [00:02:30] Speaker 03: The court still went on and found it ineligible, the claimed invention. [00:02:35] Speaker 03: And it did so based on, one, a misunderstanding where the court held that a novel order combination [00:02:46] Speaker 03: is not patentable unless it's in the manufacturing context. [00:02:50] Speaker 03: And then secondly, the court's opinion is full of findings that what the court referred to as arguments by skill survey were not persuasive. [00:03:04] Speaker 03: And this is the motion to dismiss context. [00:03:08] Speaker 03: And whether or not something is persuasive to a judge, subjectively, is not the standard. [00:03:16] Speaker 03: is and should be based on the evidence of record, which in this case was, worthy, detailed factual allegations of the complaint, which went directly to the factual issues which underpin section 101, as well as the intrinsic record of the patent, but also the PTO findings, which [00:03:40] Speaker 03: by law should have been taken as true, not vetted as arguments, not evaluated as persuasive or not, and certainly construed in favor of skill survey. [00:03:52] Speaker 03: But that wasn't the approach taken by the court. [00:03:56] Speaker 03: This raises a number of issues for this court, one of which is, is it a subjective standard? [00:04:03] Speaker 04: The PTO findings just remind me, what are those? [00:04:08] Speaker 03: So in the reasons for allowance of these claims, which were post-ALIS, the patent office issued two pages of reasons for allowance. [00:04:19] Speaker 03: They're both irrelevant. [00:04:22] Speaker 03: Do you happen to have a? [00:04:22] Speaker 03: Yes, Your Honor. [00:04:23] Speaker 03: It's appendix 250 and 251. [00:04:27] Speaker 03: Thank you. [00:04:33] Speaker 03: These are very relevant because [00:04:36] Speaker 03: The defendant says they're all related to prior art. [00:04:39] Speaker 03: They're not. [00:04:39] Speaker 03: The second finding says further, this action application is also allowed for the order slash steps in which these limitations take place. [00:04:50] Speaker 03: For instance, before the interview is conducted. [00:04:54] Speaker 03: And that is completely contrary to the traditional method that's set forth in the patent, in the intrinsic record, where reference checking was done as a throwaway step after an interview. [00:05:08] Speaker 03: These inventors moved it before. [00:05:11] Speaker 03: Why? [00:05:12] Speaker 03: Because they came up with a very particularized implementation, a very novel ordered combination, which [00:05:24] Speaker 03: aggregated the responses of the multiple references and assured confidentiality based on that because those aggregated responses that were statistically scored couldn't be hearkened back to any particular individual. [00:05:42] Speaker 01: The result as the patent states. [00:05:44] Speaker 01: Going back to that reason for allowance being that all these steps take place before the interview. [00:05:51] Speaker 01: Is your position, then, that that comes from the wear-in clause in the claim? [00:05:56] Speaker 01: Because arguably, that says we're in at least one reference report is configured to allow at least one first employer to decide whether or not to conduct the job interview. [00:06:07] Speaker 01: I mean, it's the kind of limitation, it being a wear-in limitation, it's just allowing these steps to occur before the interview. [00:06:15] Speaker 03: Your honor, our position, respectfully, is that it requires it. [00:06:22] Speaker 03: If you do it after the interview as conventional, you wouldn't infringe. [00:06:27] Speaker 03: There's certainly no preemption in that respect. [00:06:30] Speaker 03: And so it is a meaningful restriction on the claim, as is the first part of the reasons of allowance, which is a full page that goes on and recognizes [00:06:43] Speaker 03: At least it's multiple particularized steps, but what they are is this aggregation, combination of multiple references who are assured of confidentiality. [00:06:56] Speaker 03: Why? [00:06:56] Speaker 03: Because they're told your responses are going to be combined. [00:07:02] Speaker 03: No one will know what you responded. [00:07:03] Speaker 03: The results are what matter. [00:07:05] Speaker 03: You get more candid, honest feedback, and it becomes a more effective, [00:07:12] Speaker 03: hiring decision based on those results. [00:07:15] Speaker 03: And again, that was found to be novel and not obvious. [00:07:19] Speaker 03: And again, that's 102 and 103, but not conventional. [00:07:23] Speaker 04: And so here you have a- And when you say what's found, you mean by the examiner now or- By the examiner. [00:07:28] Speaker 04: And then there was no- I thought at the very beginning of your argument, you referred to the district court having so found as well. [00:07:37] Speaker 03: Is that right? [00:07:37] Speaker 03: So the district court didn't address the findings of the PTL. [00:07:41] Speaker 03: The district court, however, in its decision at page A406 said, here, a novel ordered combination. [00:07:52] Speaker 03: And then it went on to reject that as being a basis for patentability because it was not in the context of manufacturing. [00:08:03] Speaker 01: What about the idea that the Supreme Court has told us a few times now that even if [00:08:10] Speaker 01: be an eligible idea, whether it be an abstract idea, naturally occurring subject matter, even if that is novel and non-obvious, you still have to, that's not enough. [00:08:24] Speaker 01: That there is a discovery, for example, that's amazing and non-obvious doesn't mean that it escapes the one-on-one review. [00:08:34] Speaker 03: Yes, the Supreme Court has said that, and I believe it was in the Mayo context. [00:08:38] Speaker 01: And that's when you have a natural- It probably applies to the abstract idea context as well. [00:08:41] Speaker 01: It certainly does, and it was applied. [00:08:43] Speaker 01: So if the abstract idea itself is what's providing the novelty, or the thing that's not obvious, then how do we get around that? [00:08:55] Speaker 03: So here we have an abstract idea that is so generalized, it's not tied to the limitations. [00:09:00] Speaker 03: And so you've got an issue on step one and step two. [00:09:03] Speaker 03: And in answer to your question, Your Honor, what the court said is novelty isn't this question. [00:09:12] Speaker 03: It could be interrelated, but there are factual underpinnings that are specific and related to novelty. [00:09:20] Speaker 03: And that is whether it's conventional or traditional. [00:09:22] Speaker 03: Here, there was no evidence whatsoever. [00:09:26] Speaker 03: And you have to compare the claim to invention to what was traditional and conventional. [00:09:31] Speaker 03: That's a prerequisite. [00:09:33] Speaker 03: and see if that ordered combination is eligible over it. [00:09:37] Speaker 03: Here, there were no findings whatsoever, nor could there be, because there was absolutely no evidence of what was traditional or conventional, except for what's in the patent, which was a phone interview, interpersonal, which this invention revolutionized by its very specific ordered combination of steps [00:10:00] Speaker 03: a third-party computer that had all these assurances of anonymity. [00:10:07] Speaker 03: And as a result, they found they got more candid, honest feedback, which led to more reliable, accurate results. [00:10:15] Speaker 03: All of this is alleged in the complaint. [00:10:19] Speaker 03: All of this is stated in the patent as being the most important results in columns 6 and 8. [00:10:25] Speaker 01: So just assuming for a minute that this wasn't on 12b6 and there was some prior art that was available that talked about outside of the computer context, anonymously seeking reference checking, maybe checking for law firms or something like that, anonymously checking to see what the feedback is. [00:10:48] Speaker 01: and then the interview occurs after the reference checking occurs. [00:10:53] Speaker 01: If that kind of evidence was in the record, then you might have a different position. [00:10:57] Speaker 01: But I think what you're saying is one of the things that makes this satisfy step two is that under 12b6, you have to assume that all of this is novel and non-obvious. [00:11:09] Speaker 03: Absolutely. [00:11:09] Speaker 03: That's our frontline argument. [00:11:11] Speaker 03: This was prematurely dismissed. [00:11:13] Speaker 03: The record evidence is 100% on the side of the patentee here. [00:11:18] Speaker 03: in terms of the patent office findings, which stand alone as material findings of unconventional nature of the invention and the ordered combination of steps being eligible. [00:11:31] Speaker 03: That has to be construed in our favor as well. [00:11:34] Speaker 03: The factual allegations, which are fully supported by the patent, so the intrinsic record. [00:11:38] Speaker 03: The patent says the traditional is a phone interview. [00:11:42] Speaker 03: Interpersonal, it was a waste of time. [00:11:45] Speaker 03: Everyone viewed it that way. [00:11:46] Speaker 03: These inventors came up with a technology-based solution that is a third party. [00:11:52] Speaker 03: And so the example is used by the district court to show preemption. [00:11:56] Speaker 03: And there is no preemption here whatsoever. [00:11:59] Speaker 01: No rest. [00:12:00] Speaker 01: What about the district court statement that the idea at the heart of the patent is anonymously surveying prior employers, and that all these steps in the claim could be performed in the mind? [00:12:13] Speaker 01: I mean, setting the date. [00:12:15] Speaker 01: Novelty and obvious, because obviously that has nothing to do with eligibility. [00:12:20] Speaker 01: I mean, really, they're separate determinations, 101 versus 102 and 103. [00:12:26] Speaker 01: What about the fact that the district looked at it and said, overall, this is something that could be performed in someone's mind, or these steps could have been performed, and so therefore, it's not eligible. [00:12:37] Speaker 01: Just saying, I'm going to do this on a computer now. [00:12:39] Speaker 03: So with all due respect to the district court, and I do believe I'm over my time, but I'd like to answer your question. [00:12:46] Speaker 03: With all due respect to the district court, first of all, it can't be done by the mind. [00:12:51] Speaker 03: It's the anonymity that's found here. [00:12:54] Speaker 03: And this is supported by the documents cited in the complaint. [00:12:58] Speaker 03: It can't be obtained through a human interpersonal interaction. [00:13:03] Speaker 00: Secondly, there's- Not through an agency or something like that? [00:13:06] Speaker 00: It required- Like a household employment agency? [00:13:10] Speaker 03: Well, it does require a third party in the examples used by the court, where if an employer were to use this and go out and seek references, that's not preemptive. [00:13:18] Speaker 03: You can do that. [00:13:19] Speaker 03: This is really, every step, every unique step of this is set up to ensure anonymity, including the aggregation of the scores, which no one had done in the art whatsoever. [00:13:33] Speaker 03: In the mind, when you get to the dependent claims, there's absolutely no way. [00:13:37] Speaker 03: There are specialized databases where, say you're interviewing nurses at a hospital facility, those specialized databases that are claimed, you can compare them, benchmark their scores, their aggregated scores, against 10,000 nurses across the industry. [00:13:57] Speaker 03: That can't be done in the human mind. [00:13:59] Speaker 03: And the district court didn't even reach the dependent claims. [00:14:03] Speaker 03: And again, I'm over my time. [00:14:07] Speaker 03: I'd like to reserve some. [00:14:08] Speaker 03: I'm happy to answer whatever other questions. [00:14:11] Speaker 04: Why don't you reserve the remainder? [00:14:13] Speaker 03: Thank you. [00:14:22] Speaker 02: Good morning, Your Honors. [00:14:23] Speaker 02: Michael Saxtetter of Fenwick and West on behalf of Checkster. [00:14:27] Speaker 02: May it please the court. [00:14:29] Speaker 02: This is another in a long line of cases in which this court has found a patent ineligible for doing nothing more than automating a longstanding economic practice or manner of organizing. [00:14:40] Speaker 04: It's not yet another of the cases in which we have so found. [00:14:44] Speaker 02: That is a good way. [00:14:45] Speaker 02: That's actually correct. [00:14:46] Speaker 02: You want it to be. [00:14:47] Speaker 02: Yes, I do want it to be. [00:14:48] Speaker 02: And I believe it is properly resolved that way. [00:14:52] Speaker 02: But this is a case that at least the district court concluded, and we believe correctly, that this is simply a method of automating what has been a long-standing practice, a long-standing manner of organizing human activity. [00:15:08] Speaker 02: If you look at the patent itself, which is the primary evidence here, and is referenced in the complaint, is attached to the complaint, [00:15:19] Speaker 02: And if you start with the abstract and work your way through to the field of the invention, the summary of the disclosure, the detailed description of the invention, all of those describe the invention as basically having three steps, collecting data, analyzing the data, and then generating a report based on that analysis. [00:15:39] Speaker 02: This court has time and again, in numerous cases, fair warning in the electric power group case, has determined that those three steps are abstract. [00:15:49] Speaker 02: that it is something that does not add anything to an abstract idea. [00:15:55] Speaker 02: To the extent there is any broadening of the abstract idea here, from what I hear, it is either in the process of anonymity or it's in the process of performing the reference checking. [00:16:11] Speaker 02: prior to doing the interview. [00:16:13] Speaker 02: Both of those, if we compare the claims and the analysis to prior decisions of this court, which several cases of this court say that's the way that it gets done, is by reasoning, by analogy. [00:16:29] Speaker 02: Then we again find that, for instance, the order of steps that is performed is something that this court in Ultramershal found was not patent eligible. [00:16:42] Speaker 02: That in that case, the advertising was provided before the content. [00:16:47] Speaker 02: And that was sort of what was determined to be the key step. [00:16:50] Speaker 02: But that was the abstract idea behind the patented invention. [00:16:55] Speaker 02: in this case to the extent that the timing of when the interviews are conducted is relevant, then that is again part of the abstract idea and it is simply a process in the patent of automating that abstract idea. [00:17:10] Speaker 02: Turning to the question of anonymity, it is done simply by using a computer as a third party intermediary. [00:17:19] Speaker 02: Going all the way back to Alice, that's something that has been part of an abstract idea. [00:17:24] Speaker 02: That's something that has been no more than a mere conventional addition to the extent that we get to considering that in the second step of the Alice inquiry. [00:17:36] Speaker 02: It's also dead on point with the mortgage rate or case. [00:17:41] Speaker 04: Remind me, what is the anonymity here? [00:17:44] Speaker 04: Obviously, somebody is calling or [00:17:49] Speaker 02: My understanding of what my friend has said was that because you have a computer you are able to anonymously and confidentially solicit these references [00:18:04] Speaker 04: Well, the references are right. [00:18:06] Speaker 04: Somebody must have names of the references. [00:18:08] Speaker 02: You're not sending out to 350 million people. [00:18:11] Speaker 02: That's true. [00:18:12] Speaker 02: But then the references are providing the information on the applicant. [00:18:20] Speaker 02: and that information is then aggregated. [00:18:23] Speaker 02: But that's something that any employment agency could do, that any headhunter can do. [00:18:30] Speaker 02: Something that my firm does when we evaluate associates. [00:18:34] Speaker 02: It isn't exactly the same thing, but we have a numerical scale and we aggregate that scale and consider where they fall on a continuum based on that scale. [00:18:43] Speaker 02: That is something that is just a conventional process that gets done all the time. [00:18:48] Speaker 02: And the computer doesn't add anything to that, except that maybe it can do the math faster. [00:18:54] Speaker 02: But this court and the Supreme Court have found time and time again, that is not enough to add an inventive step. [00:19:00] Speaker 04: And mortgage grader was the one about anonymously shopping for mortgage rates. [00:19:07] Speaker 02: Exactly. [00:19:08] Speaker 02: Exactly. [00:19:09] Speaker 02: And we think that that case is on all fours with this case. [00:19:13] Speaker 02: To the extent that there's any kind of an unconventional addition being asserted to be added, and we don't think it is at all, [00:19:20] Speaker 02: then mortgage greater is exactly that kind of claim. [00:19:24] Speaker 02: It provides anonymity by using a computer. [00:19:28] Speaker 02: And that's what is asserted here as I understand Skill Survey's argument. [00:19:34] Speaker 02: I'd like to discuss briefly the notice of allowability issue. [00:19:40] Speaker 02: I think there are several things to say about that. [00:19:42] Speaker 02: First, if you look at the notice of allowability [00:19:44] Speaker 02: It's all one large paragraph. [00:19:46] Speaker 02: And it begins with the examiner saying, the cited patents of record do not teach. [00:19:52] Speaker 02: And then it lists a number of claim limitations from the asserted claims. [00:19:58] Speaker 02: And then, in the same paragraph, Bennett says, it gives another reason for distinguishing the prior art that was of record. [00:20:07] Speaker 02: And it says, this application is also allowed. [00:20:10] Speaker 02: because of the order in which the steps are recited in the claim. [00:20:13] Speaker 02: For instance, all the limitations take place before the interview is conducted. [00:20:18] Speaker 02: So I don't read that, and I don't think it's reasonable to read that, as doing anything other than saying, and here's another reason [00:20:24] Speaker 02: that the prior art that was before the examiner does not teach the claimed invention. [00:20:31] Speaker 02: And as this court has said, for instance, in the synopsis case, novelty does not equate to patent eligibility under Section 101. [00:20:41] Speaker 02: So even though the examiner determined that, arguably, that there was novelty, the examiner didn't expressly address patent eligibility at all. [00:20:55] Speaker 02: In fact, the examiner had the first set and only the first set of instructions post-ALIS concerning that and those set out a pretty detailed, you know, you do step one of ALIS, you determine if there's an abstract idea, if you [00:21:10] Speaker 02: find that it's an abstract idea, and then you go to step two of Alice. [00:21:13] Speaker 02: There's nothing expressly that says that that analysis was performed at all in the notice of allowability. [00:21:21] Speaker 02: Third. [00:21:22] Speaker 01: We presume that it was undertaken, right? [00:21:24] Speaker 01: I mean, we're supposed to presume that the examiner, in fact, did her job and that she considered that, right? [00:21:31] Speaker 02: Of course. [00:21:32] Speaker 02: But even if that was the case, [00:21:35] Speaker 01: It doesn't mean we have to remove it, but there's a presumption there that the patent's valid. [00:21:42] Speaker 02: I think that's correct, Your Honor. [00:21:43] Speaker 02: Or at least there's a presumption that the examiner considered that issue. [00:21:49] Speaker 02: But this court is not bound by what the examiner determined regarding that, regardless of whether it is stated expressly. [00:21:58] Speaker 02: And we don't think it is. [00:21:59] Speaker 02: We think that's purely a discussion of the Section 102 and 103 issues rather than the Section 101 issue. [00:22:07] Speaker 02: But even if it were, it's not binding on this court. [00:22:11] Speaker 02: The fact that it was post-Alice, we don't think is significant. [00:22:15] Speaker 02: And the reason for that is that the examiner did not have the benefit of significant case law that this court has developed post-Alice and post the [00:22:26] Speaker 02: the notice of allowability. [00:22:29] Speaker 02: Most notably, the Ultramershal case, which came back on remand to this court, had not been issued by this court yet. [00:22:41] Speaker 02: And this court addresses, in Ultramershal, addresses, again, the order of steps. [00:22:46] Speaker 02: So that was not precedent that the examiner had before her when she considered this application. [00:22:53] Speaker 02: I do want to note also there's some reference in the briefing to decades of prosecution for the 416 patent. [00:23:02] Speaker 02: In fact, those decades were all for parent application. [00:23:06] Speaker 02: The 416 was filed on Labor Day and was issued around Thanksgiving. [00:23:12] Speaker 02: So there were no office actions. [00:23:14] Speaker 02: This is the only communication of substance from the patent office concerning the claims that are at issue today. [00:23:24] Speaker 02: There's also some discussion in the briefing of statements that were made in advertising or were purported to have been made in advertising by Checkster. [00:23:35] Speaker 02: And in one case, a quote of a statement that is supposed to have been made by a Checkster customer rather than employee. [00:23:48] Speaker 02: And that is not something that we think can outweigh [00:23:53] Speaker 02: the evidence of the specification and the claims which show and specifically talk about the conventional computer implementation of this idea. [00:24:09] Speaker 02: There's one part of the specification that refers to generating the webpages and links where you go and fill out the form. [00:24:18] Speaker 01: What column are you looking at? [00:24:22] Speaker 02: One moment, please, Your Honor. [00:24:27] Speaker 02: It is column four, beginning at line 59, actually beginning at line 51. [00:24:34] Speaker 02: The web pages are generated by a conventional database web page generating engine, such as PHP, hypertext preprocessor, in conjunction with a relational database program. [00:24:45] Speaker 02: I don't think there's any kind of an assertion that any of this is unconventional computer technology. [00:24:51] Speaker 02: At one point, there's a reference that you can use any computer. [00:24:54] Speaker 02: And it just adds nothing. [00:24:57] Speaker 02: It adds nothing inventive to the abstract idea that is inherent in the patent itself. [00:25:04] Speaker 02: The district court closed its order by saying that the 416 Patents of Time honored process reference checking [00:25:15] Speaker 02: Taking this traditional process and computerizing it is not enough. [00:25:19] Speaker 02: Anonymity of the data is not enough. [00:25:24] Speaker 02: Encouraging clients to use the method before interviewing applicants is not enough. [00:25:29] Speaker 04: Where, if anywhere, did the district court say that not only is anonymizing data not enough, that anonymizing data is actually itself familiar, conventional, traditional, whatever the relevant word is? [00:25:46] Speaker 02: I'm not sure where that is, Your Honor. [00:25:49] Speaker 02: I'd have to search for it. [00:25:50] Speaker 02: He says at the very conclusion that it is insufficient, that merely anonymizing data is insufficient for obtaining patentability in this case. [00:26:05] Speaker 02: Again, it is the process of anonymizing is through use of a computer as a third-party intermediary [00:26:15] Speaker 02: Again, that's the mortgage grader case. [00:26:17] Speaker 02: That's Alice itself, in a way. [00:26:20] Speaker 02: Unless the court has other questions. [00:26:23] Speaker 02: Thank you. [00:26:24] Speaker 04: Thank you. [00:26:32] Speaker 04: Mr. Pettis, you have a bit over two minutes. [00:26:35] Speaker 03: Thank you. [00:26:35] Speaker 03: So first, Your Honor, focusing on that conclusion where the court [00:26:39] Speaker 03: was just discussing, there was some language that was omitted from the reading, and that is the language where the courts explicitly recognize the improvements that this specialized order of steps delivers, which is it improved the process, it provides more helpful data-driven responses, and it improves the quality of the recommendations. [00:27:02] Speaker 03: And so that's some of the new and useful results [00:27:06] Speaker 03: that are also alleged in the complaint. [00:27:08] Speaker 04: And based on those new and useful results and the unconvention... Haven't we said a number of times that taking information and [00:27:21] Speaker 04: being intelligently and even novelty selective, novelty about what information you're going to gather and what information you're going to set next to other information for viewing can really be quite useful to people, but it's not in the relevant protected field of Title 35. [00:27:42] Speaker 03: There's other cases, however, your honor, which do not find something ineligible simply because there's a manipulation of data. [00:27:51] Speaker 03: The McGrow case is one of them, where there was a specialized means. [00:27:56] Speaker 03: All these steps were in the prior art, but that specialized means, which rendered data into a different format, which is what we have here. [00:28:05] Speaker 03: And the patent office, it's a very meaningful requirement, which is the words that McGrow uses. [00:28:12] Speaker 03: How do we know that? [00:28:13] Speaker 03: Because the patent office, in its prior art evaluation, [00:28:18] Speaker 03: highlighted the limitation that rendering of the data into a different format, the aggregation of it into statistical scores so that it's kept confidential from the employer so that you get the more candid feedback. [00:28:36] Speaker 03: That is an important step. [00:28:38] Speaker 03: It's unconventional. [00:28:39] Speaker 03: It hasn't been done. [00:28:41] Speaker 03: And under Alice and GASCOM, [00:28:44] Speaker 03: If you have an unconventional arrangement, which is what we have here, and it's innovative, they have spawned an industry with this. [00:28:54] Speaker 03: And I know those things are something for another day, but it's meaningful. [00:29:00] Speaker 03: It made a difference to the Padding Office. [00:29:03] Speaker 03: And the Padding Office found that the order slash steps, at least on a motion to dismiss, those are words [00:29:11] Speaker 03: It doesn't say the prior art. [00:29:13] Speaker 03: Those are words under 101. [00:29:15] Speaker 03: There was an explicit finding. [00:29:17] Speaker 03: It's reasonable to construe it. [00:29:20] Speaker 03: And the patent office is assumed to be a person of skill in the art. [00:29:25] Speaker 03: This is not a subjective standard. [00:29:28] Speaker 03: This standard should, like all the other standards out there, the cases don't address it yet. [00:29:33] Speaker 04: You don't quite sound like you're preparing to wrap up, you should be. [00:29:37] Speaker 04: You're over time, aren't you? [00:29:39] Speaker 04: You are over time. [00:29:40] Speaker 03: I'm sorry. [00:29:41] Speaker 04: You're out. [00:29:44] Speaker 04: Thank you. [00:29:44] Speaker 04: Thank you very much. [00:29:49] Speaker 04: The case is submitted.