[00:00:09] Speaker 03: Okay, our second case this morning is number 17, 1704, Coho Licensing LLC versus Oath Inc. [00:00:17] Speaker 03: Ms. [00:00:17] Speaker 03: Scott. [00:00:53] Speaker 00: Morning, Your Honors. [00:00:54] Speaker 00: May it please the Court? [00:00:56] Speaker 04: The critical issue in this case is... In the red brief at 64 to 68, oath says that on appeal you've only preserved specific argument with respect to claims 1 to 3, 8 and 9, and 14 of the 395 Patent, 5, 10, 12 to 13, and 17 of 096, and claims 2 and 3 of 065. [00:01:21] Speaker 04: Is that a correct list? [00:01:26] Speaker 01: Your Honor, I believe that is a correct list. [00:01:28] Speaker 01: I actually did not double-check it, but I would like to speak to the fact that, yes, in the district court level, we addressed several of the dependent claims, the limitations of the dependent claims in detail. [00:01:41] Speaker 01: However, the district court did not analyze, failed to analyze the dependent claims in its order. [00:01:46] Speaker 01: AOL also failed to meet its burden of proving [00:01:49] Speaker 01: I apologize, Your Honor. [00:01:55] Speaker 04: Is that the correct list? [00:01:57] Speaker 01: I believe it is, Your Honor. [00:01:59] Speaker 04: I take that as a yes, then. [00:02:02] Speaker 01: Yes, I can double-check it real quick, Your Honor, or I can get back to you. [00:02:05] Speaker 04: Well, because my next question is, if so, if that's a correct list, which other claims should be considered, and where in your opening brief did you make specific arguments regarding the limitations of those claims? [00:02:18] Speaker 01: Yes, Your Honor. [00:02:20] Speaker 01: Well, in the opening brief, we discussed the dependent claims beginning on page 16, going through page 18. [00:02:37] Speaker 01: And then we also discussed the dependent claims in detail beginning on page 37, going in through page [00:02:50] Speaker 04: I'm trying to do housekeeping, Your Honor. [00:02:53] Speaker 01: Yes, Your Honor. [00:02:53] Speaker 04: And I'm trying to get your help. [00:02:55] Speaker 04: You should know the record. [00:02:57] Speaker 01: Yes, Your Honor. [00:02:58] Speaker 04: You should know your brief. [00:02:59] Speaker 01: Yes, I do, Your Honor. [00:03:00] Speaker 04: OK. [00:03:01] Speaker 04: Then you can answer my question. [00:03:04] Speaker 01: I'm sorry. [00:03:05] Speaker 01: Your question was whether or not we provided the only place that we provided. [00:03:10] Speaker 01: We briefed the exact same dependent claims. [00:03:12] Speaker 04: Is there anything else? [00:03:13] Speaker 04: And so where? [00:03:14] Speaker 01: No, Your Honor. [00:03:15] Speaker 01: It's on page 37 through 44 are the dependent claims. [00:03:18] Speaker 04: So there is nothing else. [00:03:20] Speaker 01: What do you mean by nothing else, Your Honor? [00:03:23] Speaker 04: All right. [00:03:24] Speaker 04: Let me go back. [00:03:27] Speaker 01: I apologize. [00:03:27] Speaker 01: Yes, Your Honor. [00:03:28] Speaker 01: I believe that they listed the correct number of claims. [00:03:32] Speaker 04: And you haven't raised anything else? [00:03:35] Speaker 01: I do not believe we raised any additional claims in the briefing. [00:03:41] Speaker 01: It's possible that dependent claims to... I'm trying to establish a universe. [00:03:45] Speaker 01: I apologize? [00:03:46] Speaker 04: I'm trying to establish a universe. [00:03:48] Speaker 01: Okay. [00:03:48] Speaker 01: Yes, Your Honor. [00:03:49] Speaker 01: I do, in answering your report, I do believe that claim 2 of the 395 patent, which is on page 41 of the blue brief, I do not believe that that was included in the district court briefing. [00:04:02] Speaker 04: Okay. [00:04:04] Speaker 04: Thank you. [00:04:09] Speaker 04: Thank you. [00:04:10] Speaker 00: Yes, Your Honor. [00:04:10] Speaker 00: Thank you. [00:04:13] Speaker 02: So back to where you started. [00:04:15] Speaker 02: Is that the critical issue? [00:04:16] Speaker 01: Yes, Your Honor. [00:04:17] Speaker 01: Thank you. [00:04:17] Speaker 01: The critical issue before the court today is whether a district court can, at a Rule 12 motion, find patents ineligible without providing any analysis in the order, without mentioning the technical limitations of the dependent claims, and refusing to consider the relevant evidence presented by the patent holder. [00:04:36] Speaker 01: First, the district court erred by failing to consider and analyze the technical limitations set forth in the dependent claims. [00:04:44] Speaker 03: Well, what is it about the dependent claims that's different from the independent claim one that was analyzed by the district court? [00:04:53] Speaker 01: Yes, Your Honor, there's several differences. [00:04:56] Speaker 01: Two of the dependent claims that we focused the most on, both at the district court level and at this court, was claim 12 of the 096 patent, which contains the consideration of available resources limitation. [00:05:10] Speaker 01: This limitation in and of itself is non-abstract and inventive and should have been considered on its own. [00:05:17] Speaker 01: Claim 12 is a dependent claim of claim 8 of that patent, which sets forth this. [00:05:22] Speaker 03: Why does that make it non-abstract? [00:05:24] Speaker 03: I mean, that was a criterion, wasn't it, in the prior art specifically referenced in the patent, right? [00:05:35] Speaker 01: No, Your Honor. [00:05:36] Speaker 01: The prior art did not contain any [00:05:39] Speaker 01: consideration of available computer resources limitation. [00:05:42] Speaker 01: And in fact, the non-abstractness and inventiveness of this is the fact that at the local computer level, the local computer is able to track the availability of computer resources and to sub-allocate tasks based on the availability by first determining the availability of computer resources. [00:06:03] Speaker 03: refers to switching an allocated task portion to a different computer if the one first assigned the task portion becomes occupied. [00:06:15] Speaker 03: And this describes some of the resource factors involved in determining whether to allocate. [00:06:19] Speaker 03: So this prior art that your own patent describes talks about allocating based on resource factors, right? [00:06:29] Speaker 01: No, Your Honor. [00:06:30] Speaker 01: So the prior art system, [00:06:33] Speaker 01: is a one-tier, single-division system in which the initial allocating computer allocates a task to another computer. [00:06:42] Speaker 03: Considering resources, right? [00:06:45] Speaker 01: So the difference in the COHO patents, Your Honor? [00:06:47] Speaker 03: Does it consider resources? [00:06:49] Speaker 01: The initial allocating computer might, Your Honor, but the local computer does not consider network resources. [00:06:54] Speaker 01: And that's what is novel and unconventional about the COHO patents. [00:06:58] Speaker 01: The COHO patents claim technology that at the local computer level, the local computer is actually the one that's making the decision based on a network of factors. [00:07:09] Speaker 03: But that's the same thing as making the decision to subdivide the work further, right? [00:07:15] Speaker 01: Yes, but it is doing so based upon network factors, such as whether or not there's computer failure, whether or not there's network latency. [00:07:22] Speaker 01: And that was not claimed in this top-down approach by the prior art. [00:07:25] Speaker 01: The top-down approach by the prior art [00:07:27] Speaker 01: only has the initial allocating computer doing one division, sending it to a computer, which if there is an error at that local computer in the prior art, then the local computer has to send that task back up to the initial allocating computer. [00:07:42] Speaker 02: And that is less efficient than the technology claimed in the COHO patents, where in COHO... The column three, you specifically say, note that the term allocate and its conjugations may refer to initial allocation or subsequent sub-allocation [00:07:57] Speaker 02: After all, the allocation process is self-similar. [00:08:01] Speaker 02: And you go on to further describe how essentially it's the same thing, only doing it over again. [00:08:08] Speaker 01: Yes, Your Honor. [00:08:09] Speaker 01: Essentially, it is self-similar. [00:08:11] Speaker 01: There is another allocating. [00:08:14] Speaker 01: There is another portion. [00:08:16] Speaker 01: It's being repeated. [00:08:17] Speaker 01: In rapid litigation, this court said that repeating a step can be found to be an inventive concept, can be found to be patent eligible. [00:08:25] Speaker 01: But this, the COHO technology actually goes beyond repeating a step. [00:08:30] Speaker 01: It actually, it's the consideration at the local level of the network factors. [00:08:37] Speaker 01: It's the division, the allocating, and the transferring steps at the local level, which the PTAB actually found those steps to be... What do you mean at the local level? [00:08:45] Speaker 03: It just means that you're doing the same thing when you consider a subdivision that you did when you considered division in the first place, right? [00:08:55] Speaker 01: Correct, but it's being done at a different level. [00:08:57] Speaker 01: So in the prior art, Your Honor, you would have an initial allocating computer which would send a task to a computer below. [00:09:04] Speaker 01: If there was a problem at that second computer, at that below computer, if that computer was failing, if it was running slow, if there were storage capacity issues, then that computer would have to send the task back up to the initial allocating computer, and then the initial allocating computer would have to send the task back down to whatever computer it wanted to send it to. [00:09:23] Speaker 01: Whereas here, the initial allocating computer sends the task down to the local computer, sub-allocating computer. [00:09:31] Speaker 01: And the sub-allocating computer is able to determine based on computer resources, network factors, that this computer is not behaving properly. [00:09:43] Speaker 01: This computer is failing. [00:09:44] Speaker 01: This computer doesn't have enough storage space. [00:09:46] Speaker 01: And based on that, determination is then able to send the task on. [00:09:51] Speaker 01: So you're essentially skipping several steps. [00:09:54] Speaker 03: You're not having to send it back up. [00:09:56] Speaker 04: It's acting just like the initial allocating computer, is it not? [00:10:02] Speaker 01: Well, it is acting as the initial allocating computer in that it is able to divide, subdivide, [00:10:10] Speaker 01: at this task to allocate the task and to transfer the task yes correct but that was something that was not found in the prior art your honors. [00:10:17] Speaker 01: I don't see anything in the specification that describes that as new that says the prior art couldn't accomplish X or Y or Z. Yes your honor if you turn to column one for instance APPX 118 this is in the 395 patent but the [00:10:39] Speaker 01: Patents share the specification. [00:10:43] Speaker 01: At line 52, it talks about US patent numbers 388 and 225. [00:10:51] Speaker 01: And it describes the same computer was being used for allocating, monitoring, and reallocating task portions. [00:11:02] Speaker 01: So in the prior art, it was this one computer, this initial allocating computer that was doing all the steps. [00:11:09] Speaker 03: Would you agree that the second step here, the reallocating, is done exactly the same way that the initial allocation was done, right? [00:11:19] Speaker 01: Well, Your Honor, the- Yes or no? [00:11:23] Speaker 01: No, because, I mean, the P tab- No, you did not agree with me when I asked you that question? [00:11:30] Speaker 01: I apologize. [00:11:33] Speaker 01: Do you mind restating the question? [00:11:35] Speaker 03: The question is whether when the second tier computer does the reallocating, is it doing the same thing, the same process that the original computer did in the initial allocation? [00:11:49] Speaker 01: It is, but it's doing it at the local level. [00:11:51] Speaker 01: And that's important for multiple reasons. [00:11:54] Speaker 01: It wasn't found in the prior art. [00:11:56] Speaker 03: Is that the inventive concept? [00:11:57] Speaker 01: Yes, it's one of the inventive concepts, Your Honor. [00:11:59] Speaker 03: What other inventive concept is there? [00:12:02] Speaker 01: The fact that [00:12:03] Speaker 01: there is a multi-tiered distribution that was not found in the prior art. [00:12:09] Speaker 01: And then within the context of the dependent claims, there are also other inventive concepts which were not considered by the district court in its order. [00:12:21] Speaker 01: And the district court, I mean, one of the major errors here is that the district court failed to even consider these limitations. [00:12:26] Speaker 02: But where in the specification do you discuss the concept of this [00:12:32] Speaker 02: doing this allocation at a local level being unique or novel, or even describe how it's done. [00:12:39] Speaker 01: Yes, Your Honor. [00:12:40] Speaker 01: Well, for example, column 1, APPX 118 again, beginning... So other than referring to a prior patent that didn't do it. [00:12:52] Speaker 01: Yes, Your Honor. [00:12:53] Speaker 01: It happens to be the same column. [00:12:55] Speaker 01: Oh, no. [00:12:56] Speaker 01: No, Your Honor. [00:12:56] Speaker 01: That's not all. [00:12:58] Speaker 01: Column 1 of APPX 118 beginning at [00:13:03] Speaker 01: 63, line 63, discusses how in this, the COHO technology, a computer which has been allocated a distributed processing task may itself determine to reallocate a portion of its subtask, for example, in order to meet a schedule of its performance profile deteriorates before expectation. [00:13:22] Speaker 01: This was a technical problem that was set forth in the patent that was not addressed in the prior art. [00:13:27] Speaker 03: How does this patent tell you how to solve that supposed technical problem? [00:13:32] Speaker 01: Yes, Your Honor. [00:13:32] Speaker 01: This patent sets forth the solution, a specific implementation of the solution. [00:13:37] Speaker 01: For example, in figure two of the patent, which is located on page APPX 113, this shows an exemplary architecture of a network with the relational components between the computers. [00:13:52] Speaker 03: It's just describing what's claimed, right? [00:13:54] Speaker 03: It's not telling you how to do it. [00:13:56] Speaker 01: This describes, or excuse me, Figure 2 describes the architecture. [00:14:01] Speaker 01: And then if you look at Figure 3B, that describes a series of processing steps, which includes two steps of dividing a task and distributing it to the computers below. [00:14:11] Speaker 01: And then those computers at the local level can again subdivide those tasks. [00:14:17] Speaker 03: This figure says- It's just describing what's planned. [00:14:20] Speaker 03: It's not describing how to accomplish it. [00:14:23] Speaker 01: Your Honor, it sets forth the processing steps, which is describing how to accomplish it. [00:14:29] Speaker 01: And then, of course, in the claims, it also sets forth these processing steps and how to accomplish the solution. [00:14:41] Speaker 04: So if you put it into words, it would say in figure three, do it exactly the same way as the initial allocating computer. [00:14:49] Speaker 01: Well, Your Honor, I mean, it is subdividing task as the initial allocating computer is, but like I said, it's different because it's doing it at the local level and that was something that was not taught in the prayer art. [00:14:59] Speaker 01: And that's something that the P-Tab... So I just put your diagram into words. [00:15:04] Speaker 01: Excuse me, Your Honor, I didn't hear you. [00:15:05] Speaker 04: I said I just put your diagram into words, figure three. [00:15:10] Speaker 01: B. I mean, essentially, Your Honor, but I mean, it's put into words in the specification as well. [00:15:17] Speaker 01: It goes through and describes how [00:15:18] Speaker 01: you know, it's a series of processing stops and how the tasks are subdivided based upon various factors. [00:15:26] Speaker 01: And as I mentioned, Your Honor, this is very difficult. [00:15:29] Speaker 03: Do you want to save rebuttal time? [00:15:32] Speaker 03: Yes, Your Honor. [00:15:33] Speaker 03: All right, we'll give you two minutes for rebuttal. [00:15:34] Speaker 01: Thank you. [00:15:46] Speaker 03: Mr. Capps? [00:15:48] Speaker 05: Morning, Your Honors. [00:15:48] Speaker 05: May it please the court? [00:15:50] Speaker 05: I'd like to address just a couple of points that counsel for the appellant addressed. [00:15:57] Speaker 05: First, it simply is not the case that the district court ignored the dependent claims. [00:16:03] Speaker 05: The courts below opinion... Excuse me. [00:16:07] Speaker 04: That's on the face of the opinion. [00:16:10] Speaker 05: Yes. [00:16:10] Speaker 05: The court in footnote two of the opinion explicitly notes that [00:16:15] Speaker 05: He did not expressly address each asserted claim because he concluded that claim one was representative of all of the claims because they are substantially similar and linked to the same abstract idea. [00:16:28] Speaker 02: Further, there was... But it's very clear that they asked him to consider the dependent claims. [00:16:34] Speaker 02: Yes. [00:16:34] Speaker 02: We'd have to agree, and he didn't really explain much in the opinion as to why he thought it was representative. [00:16:41] Speaker 02: He just said it was. [00:16:43] Speaker 02: That's not enough, is it? [00:16:45] Speaker 02: For us to say you automatically don't have to look at the dependent claims if you just say this is representative and of inquiry? [00:16:52] Speaker 05: The court considered all of the briefing, which included briefing on behalf of the appellant, addressing specific dependent claims, which we addressed as well. [00:17:02] Speaker 05: So all of the briefing was submitted to the court, and this was addressed at oral arguments as well. [00:17:06] Speaker 05: The dependent claims were discussed. [00:17:09] Speaker 05: So I do not think that- But is the claim 12 different [00:17:12] Speaker 02: Is Claim 12 different from... I mean, it's actually different from Claim 1, right? [00:17:16] Speaker 02: It talks about doing the allocation at the sub-allocation level, correct? [00:17:23] Speaker 02: At the sub-computer level. [00:17:25] Speaker 05: That's exactly what Claim 1 describes as well. [00:17:30] Speaker 05: Claim 1 specifically talks about an initial level of dividing a task into a plurality of task portions by an allocated computer. [00:17:37] Speaker 02: Right, and they need each one and they keep getting re-divided. [00:17:40] Speaker 02: So the question is, in Claim 12, [00:17:42] Speaker 02: that there is the, not just the question of if he's getting re-divided, but the re-division decisions are made at a different level. [00:17:52] Speaker 05: No, the same concept is in claim one. [00:17:55] Speaker 05: It's the, if you look at the element, one, two, three, four, five, it says said sub-allocating computer dividing said task portion into a plurality of sub-task portions. [00:18:09] Speaker 05: That's the second level. [00:18:11] Speaker 05: It's the same as claim 12. [00:18:22] Speaker 02: So here's the real question. [00:18:25] Speaker 02: We're just accepting your lawyer argument that you think it's the same as claim 12, but the judge never explained why it was the same as claim 12. [00:18:33] Speaker 02: Does he have to do that? [00:18:35] Speaker 05: I don't think there is any precedent that requires the district court [00:18:40] Speaker 05: to write in its order and address in its order each dependent claim of the patent if the judge concludes that the dependent, that claim one is represented, a claim is representative of those claims. [00:18:54] Speaker 02: There's no requirement for him to address them. [00:18:57] Speaker 02: So how is the statement in claim one where they're reallocating, how does that subsume the concept of [00:19:06] Speaker 02: consideration of available computing resources at that stage. [00:19:11] Speaker 05: Sure, so that portion of the claim which we addressed in our briefing is merely the application again of conventional technology and it's discussed as being the prior art in the specification of this patent. [00:19:28] Speaker 05: So for example, and [00:19:35] Speaker 05: Appendix 118 in the discussion of the prior art, the specification itself notes that the prior art considered resource factors involved in determining whether to allocate a task portion to a computer, including switching an allocated task portion to a different computer if the one first assigned the task portion becomes occupied. [00:20:02] Speaker 05: determination of available resources discloses the priorities conventional technology so that that elements of claim 12 does not add anything to the to the abstract idea. [00:20:13] Speaker 02: The argument that in the prior art you actually had to to go back to the original computer if there was some question of the need to analyze computer resources when once the sub allocation occurred [00:20:29] Speaker 05: Well, that's just the nature of repeating the allocation. [00:20:34] Speaker 05: So if there is only one tier, the whole point is if one of the allocated computers is busy, that the task gets allocated to another computer. [00:20:45] Speaker 05: Of course, inherently, if you have another layer, then there are additional computers that the task can be allocated to. [00:20:52] Speaker 05: Again, that's not adding anything to the basic concept that you can divide a task multiple ways. [00:20:58] Speaker 05: It doesn't matter how many times you divide the task into how many computers, just as it would be in the case of organizing human experience. [00:21:08] Speaker 05: You could have any number of people and you could divide a task any number of ways into any number of tiers. [00:21:13] Speaker 05: That's simply an abstract concept. [00:21:15] Speaker 04: My problem with the whole thing is that there's an assumption there [00:21:20] Speaker 04: the initial allocating computer can't do a thousand different tasks at once. [00:21:28] Speaker 04: And of course it can. [00:21:29] Speaker 04: So it can have multiple initial allocations operating from the initial allocating computer. [00:21:37] Speaker 05: Correct. [00:21:37] Speaker 05: The initial allocating computer can allocate a task to a hundred different sub-computers. [00:21:49] Speaker 05: Just in addition on the point of the court having to, whether the court has to address in its opinion each of the dependent claims, this court has held in the Cleveland Clinic case and the content extractions case that that is not necessary. [00:22:04] Speaker 05: In those cases as well, there was no claim by claim discussion in the lower court's opinion, but this court held that because the claim discussed by the district court was representative, it was sufficient to [00:22:18] Speaker 05: to provide an explanation of why all of the patent claims should be invalidated. [00:22:24] Speaker 05: There's no distinction here in this case. [00:22:26] Speaker 05: In fact, if anything, there was more evidence that the district court considered the depending claims here because there was briefing on it and oral argument on those claims. [00:22:38] Speaker 02: I assume that when you filed our peers on this, you presented what you thought was the best prior art, right? [00:22:45] Speaker 02: Yes, Your Honor. [00:22:48] Speaker 02: PTAB, whether or not it's binding on the district court, specifically found that the prior art didn't disclose what this patent discloses, right? [00:22:57] Speaker 05: Correct. [00:22:59] Speaker 05: We believe that was incorrect. [00:23:02] Speaker 05: But again, the PTAB's analysis was limited to just the specific prior art that was presented to it. [00:23:08] Speaker 05: It wasn't addressing 101 question. [00:23:10] Speaker 05: And it also was not addressing 101. [00:23:14] Speaker 05: So the fact that [00:23:15] Speaker 02: I don't have any problem with those arguments. [00:23:17] Speaker 02: My point is what you're saying here is that the reason we should assume that Claim 12 isn't anything different is because the prior art all did that, and yet you didn't seem to be able to point to any prior art that did that. [00:23:33] Speaker 05: Well, the prior art that we're pointing to here is the specification itself. [00:23:38] Speaker 05: So this was disclosed in the patent. [00:23:43] Speaker 05: I don't recall now what the PTAB's decision was as to Claim 12 and whether the PTAB acknowledged that the consideration of resources was in the prior order or not. [00:23:55] Speaker 05: I would be surprised if it concluded that it was not, given the disclosure and the patent specification. [00:24:00] Speaker 04: I don't think you have to go any further than your opposing counsel's concession on the role of the initial allocating computer compared to the sub [00:24:11] Speaker 05: Correct, it's the same exact process, which is admitted in the specification. [00:24:20] Speaker 05: There really is no inventive concept by simply repeating something that is an abstract concept and is well known, and is merely being applied here in a conventional way. [00:24:32] Speaker 05: The patent specification is replete with discussions that this is [00:24:36] Speaker 05: applied to generic computers and a generic network. [00:24:40] Speaker 05: There is no specific implementation discussed anywhere in the claims, which distinguishes this case from this court's decisions finding that certain patents were patentable when there's a specific implementation discussed. [00:24:56] Speaker 05: These claims don't have that. [00:25:02] Speaker 05: Anything further? [00:25:03] Speaker 05: If there are no further questions, [00:25:05] Speaker 01: In this case, the District Court on a Rule 12C motion for judgment on the pleadings erred in failing to consider and to provide any analysis regarding the dependent claims, which in and of themselves did contain patent-eligible concepts. [00:25:33] Speaker 03: Failing to identify- Are you conceding now that the independent claim was unpatentable? [00:25:40] Speaker 01: No, Your Honor. [00:25:41] Speaker 01: We're not conceding that claim one of the COHA patents is unpatentable, if that's your question. [00:25:48] Speaker 01: We're saying that the court didn't even consider the dependent claims, which was clear error at this stage. [00:25:55] Speaker 01: It designated claim one of the 395 patent as a representative claim without even looking at, I mean, in a footnote. [00:26:03] Speaker 04: Wait a minute. [00:26:04] Speaker 04: How can you say it didn't look at it? [00:26:07] Speaker 01: Well, the only mention of the dependent claims in the order is a footnote. [00:26:12] Speaker 04: Was it argued and presented to the court? [00:26:15] Speaker 01: Yes, Your Honor. [00:26:15] Speaker 01: It was argued and presented to the court. [00:26:17] Speaker 04: So you can't say it didn't look at it. [00:26:20] Speaker 01: It heard argument on it. [00:26:23] Speaker 01: Yes, Your Honor. [00:26:23] Speaker 01: And it was in the briefing. [00:26:24] Speaker 01: Yes, Your Honor. [00:26:25] Speaker 01: However, first of all, AOL had the burden of proving that those claims were patent ineligible. [00:26:32] Speaker 01: And AOL did not meet that burden. [00:26:34] Speaker 01: And then the court further erred in not providing any sort of analysis in its order, which the court has said the Federal Circuit is not the court which should be doing the analysis. [00:26:46] Speaker 01: The district court is the court in which should be doing the analysis. [00:26:50] Speaker 02: In fairness, while the district court didn't show its work, [00:26:55] Speaker 02: in his math homework, it did say that gave a thorough analysis of the claims and the specifications. [00:27:01] Speaker 01: It did, Your Honor. [00:27:02] Speaker 01: In that footnote, it also says only that the limitations in all other claims are abstract. [00:27:09] Speaker 01: It didn't even reach the step two of the Alice analysis. [00:27:13] Speaker 01: So even if you're just looking at the footnote, that's clear error because it didn't consider step two of Alice. [00:27:20] Speaker 03: So I see my time is up, Your Honor.