[00:00:00] Speaker 02:
The court has one case before it for oral argument this afternoon.

[00:00:05] Speaker 02:
Integrated claim system versus care and care insurance company, number 16-2527.

[00:00:12] Speaker 02:
Mr. Ward, you reserve five minutes of your time for rebuttal.

[00:00:20] Speaker 03:
Ten and five, please, your honor.

[00:00:22] Speaker 02:
Yes, you're going to go ten and you're reserving five.

[00:00:24] Speaker 03:
Please.

[00:00:25] Speaker 02:
Okay, you may proceed.

[00:00:30] Speaker 03:
Good afternoon.

[00:00:37] Speaker 03:
The principal issue before us today is the board's determination that the patents in suit merely disclose the use of generic hardware with generic software.

[00:00:49] Speaker 03:
That's just not correct.

[00:00:52] Speaker 03:
We can quibble about the hardware, but more pertinent here is the software that is identified in the patents

[00:01:01] Speaker 03:
Specifically, if you turn to claim 6 of the 020 patent, which is at the appendix page 214, you'll see that claim 6 calls for

[00:01:29] Speaker 03:
the digital device as recited in claim one, wherein the digital device is a server responsive to specialized software.

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Our position, your honors, is that there is absolutely nothing generic about Dr. DiRienzo's specialized software.

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This is identified in the specifications as AIC software,

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and it's referred to over 50 times in each of the patents.

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The software allows for the creation of customizable forms for each insurance company and it's described in detail on the joint appendix page 208 and it runs essentially the entire page columns 13 and 14

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most particularly from column 13, line 11, through column 14, line 28.

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Starting at column 13, Dr. DiRienzo identified suitable programming languages, commercially available software packages that could be used as a platform for creating this AIC software, and then provides a detailed description

[00:02:57] Speaker 03:
of how this AIC software works.

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And if I could just direct your attention briefly to the next page of the appendix 210, column 18, starting at line 66 at the very bottom of the page.

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The goals of the AIC and accomplishments of the AIC software are described.

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It reads, with the AI system described above,

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The use of fields, the customizable claim form, and the placing of coordinated AIC software at both the service provider's office and the insurance company has eliminated the need for standardized forms.

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The result is that each insurance company gets exactly the information it wants and has it displayed in exactly the way it wants.

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Thus, the compromise of a standardized claim form, as is required with the present NEIC system, is avoided.

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So what the AIC software really allows that had never been done before is that you can take an attachment such as an X-ray, digitize it, and enter it into one of the fields of the

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customizable form.

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So it's never separated from the rest of the data that is inserted into the form that goes to the insurance company.

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The forms are dynamic in that they change based on information as it's entered.

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And quite frankly this functionality

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is not something that was available anywhere else when these applications were filed in 1997.

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The forms that Dr. DiRienzo discloses here are XML-like.

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At the time of filing, the common forms were HTML.

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They're different.

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XML files have to do with the description of information in the form, while the older HTML files

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deal with the display of information.

[00:05:23] Speaker 03:
So what Dr. DiRienzo provided here was something that was being worked on in industry at the time and there's an article that we had cited to the board at one point by Tim Berners-Lee who invented the internet who was working with these forms at that time in 1997.

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So they were not in the prior art.

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They were not in commercially available products like Lotus or Java

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which Dr. DiRienzo identified as platforms that could be used to build the software he was calling for.

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This was something new and it should not be deemed generic because it clearly is quite specialized and was identified so throughout the specifications and the claims.

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And further,

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The customizable forms that Dr. DiRienzo helped invent here have been covered in at least three other United States patents that have been issued to him over the course of the years.

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Finally, on this point, it's worth noting that although the software is described in some significant detail, particularly in columns 13 and 14,

[00:06:47] Speaker 03:
the board never cited to these columns in its decisions.

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We also have something of a problem with some of the things the board did rely on.

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Specifically, the board continually pointed out its opinion that the hardware and software

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disclosed in the patents was routine and well-known.

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Unfortunately, it provided absolutely no support for that position.

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In fact, the only support it provides when it makes these comments is in reference to the background of Dr. DiRienzo's patent.

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i've talked to you yet so in it attempted to honestly explain the prior art describes the situation that exists the problems that exist with uh... incompatibility between uh... standard computers and mainframes and comes about with the solution to this problem and in his description of how these uh... these technologies developed provided fairly detailed background and in shooting down the invented inventiveness

[00:08:12] Speaker 03:
and of these concepts, the board relies on nothing else other than Dr. DiRienzo's own background explaining the state of the art.

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This would certainly seem to violate the recent Burkheimer case where the court determined the questions of fact, that the

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where the court, excuse me, determined that whether something is routine or well-known to one of skill and the art is a question of fact.

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There were no facts in the board's decision in support of its conclusion.

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The board finally also ignores the inconsistencies in its finding that these inventions were well-known and routine.

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Because it doesn't point out or acknowledge that although these patents were filed in 1997, it wasn't until 2003 that the insurance industry started to adopt this method of operation, the insertion of digitized attachments into computer software fields.

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So if the problem, as pointed out by the board, is merely one

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of inefficiencies, and these inventions were simply routine and well-known, it does not explain why it took the insurance industry, which was looking for solutions and which you would presume would want efficiencies, didn't get around to adopting this method of operation for almost six years.

[00:10:07] Speaker 03:
And if I could, I'd like to reserve the rest of my time.

[00:10:10] Speaker 02:
OK.

[00:10:10] Speaker 02:
Thank you very much.

[00:10:19] Speaker 02:
Mr. Kutry, did I get your name right?

[00:10:22] Speaker 01:
It's Kutry, your honor.

[00:10:23] Speaker 01:
Kutry, okay.

[00:10:24] Speaker 01:
Thank you.

[00:10:31] Speaker 01:
May it please the court.

[00:10:32] Speaker 01:
This court should affirm the board's holdings in the 6-2, 6-3, and 6-4 proceedings below, which canceled or otherwise invalidated all of the challenge claims in the 020 and 609 patents.

[00:10:46] Speaker 01:
The first thing I wanted to point out is that

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as Your Honors may be aware, because of the filing yesterday by ICS, a previous board of the Patent Office in the Travelers Proceeding has already confirmed that the 020 patent, one of the two patents that's at issue here, is CBM eligible.

[00:11:03] Speaker 01:
And they have concluded that certain of the claims that are at issue here are unpatentable under Section 101.

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That holding was appealed to this Court.

[00:11:14] Speaker 01:
I believe, Dr. Drano, you're on that panel.

[00:11:17] Speaker 01:
And this court affirmed, via Rule 36, ICS appealed to the Supreme Court.

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In the interim, they asked for an en banc hearing that was denied.

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They appealed to the Supreme Court.

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And yesterday, the Supreme Court denied certificate served.

[00:11:30] Speaker 01:
So as we sit here today, claims 27, 30, 36, 42, 43, 45, and 50 through 52.

[00:11:39] Speaker 01:
And if Your Honor has

[00:11:44] Speaker 01:
our brief, the response brief on page 15, we tried to create a table that isolates what was at issue in travelers.

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But we have that list of the, we call them the already invalidated claims.

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They're essentially the non-patentable claims of the 020 patent.

[00:12:01] Speaker 01:
So as we sit here today, I know that the petitioner, I'm sorry, the appellant said that they wouldn't be arguing about those claims today.

[00:12:07] Speaker 01:
But in fact, we do have to have argument about those claims.

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Because in their briefing, the fact that those claims are invalid under 101

[00:12:14] Speaker 01:
disposes of this entire appeal.

[00:12:17] Speaker 01:
In the briefing below and here, ICS has always taken the position that these claims in the 020 patent, all of them rise and fall together.

[00:12:29] Speaker 01:
And if you look at their brief on page 41, this is their opening brief, they say all the claims filing of the 020 patent rise and fall together stating that quote, they are quote, not unpatentable

[00:12:42] Speaker 01:
under 35 USC section 101 for the same reasons.

[00:12:45] Speaker 01:
So we're looking at page 41.

[00:12:49] Speaker 01:
Simply put, there's no credible basis anymore if we look at 41 of their brief on the bottom paragraph for the reasons stated above.

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They basically treat the independent claims of the 020 patent and the independent claim of the 609 patent together.

[00:13:04] Speaker 01:
They have one omnibus set of arguments.

[00:13:07] Speaker 01:
And then they say the dependent claims are rise and fall together.

[00:13:11] Speaker 01:
But as you can see, claim 27, which is listed in the first paragraph, first sentence, 42 and 50 are already invalid as we sit here today.

[00:13:21] Speaker 01:
I'm sorry, they've been canceled for claiming non-patentable subject matter under section 101.

[00:13:26] Speaker 01:
There are no more appeals.

[00:13:31] Speaker 01:
There's simply no credible basis any longer to argue that these claims are not invalid under section 101.

[00:13:37] Speaker 01:
Similarly, one of the issues in the traveler's proceeding was whether these claims that are at issue here were subject to the CBM proceedings.

[00:13:45] Speaker 01:
That's an issue that the appellant lost.

[00:13:48] Speaker 01:
They've exhausted all of their appeals.

[00:13:50] Speaker 01:
These patents are eligible for CBM proceedings and they are invalid under 101.

[00:13:56] Speaker 01:
We are now up to five courts and we hope there will be six after this court that have all looked at these issues and they've all concluded that these patents are directed to non-patentable subject matter.

[00:14:08] Speaker 01:
And there's no distinction across the patents made by the appellant in any respect.

[00:14:13] Speaker 01:
So there's an additional reason that the O2O patent, the challenge claims are invalid here and that has to do with Lech and Beezer.

[00:14:19] Speaker 01:
And so when the appellant says that this was brand new and this had never been done before, that again flies in the face of the fact that there is a prior art, the Lech patent, that anticipates many of the claims and then Lech combined with Beezer

[00:14:36] Speaker 01:
is, renders the remaining claims of the 020 obvious.

[00:14:41] Speaker 01:
What's interesting is that the lech patent is actually the patent that's at issue in content extraction.

[00:14:46] Speaker 01:
So in your honor, in this court's holdings in content extraction, if you look at those claims, this court said that those claims are directed to essentially moving information around in fields.

[00:14:57] Speaker 01:
That's not patentable subject matter.

[00:14:59] Speaker 01:
That patent anticipates the claims here.

[00:15:02] Speaker 01:
And indeed, some of the claims of that

[00:15:04] Speaker 01:
lech patent are used to anticipate certain of the claim elements here.

[00:15:08] Speaker 01:
So our position is that these patents are invalid on many different bases or otherwise not patentable subject matter.

[00:15:16] Speaker 01:
I do want to talk briefly about the fields argument.

[00:15:21] Speaker 01:
Appellant's counsel did not directly say this, but they took you to a portion of the specification where they said there's a discussion of fields.

[00:15:28] Speaker 01:
There are discussions of fields in their brief as well.

[00:15:31] Speaker 01:
First, the discussion of fields from a claim construction position was never presented below and should not be considered here.

[00:15:38] Speaker 01:
Indeed, all of the arguments that you just heard were not actually presented directly as you should be interpreting the claims via the word field to incorporate all this allegedly specialized software.

[00:15:49] Speaker 01:
On claim 26, by my count in the opening brief, there are four different positions as to what claim a field should be construed as.

[00:15:58] Speaker 01:
Three of them are new.

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One of them is that fields should be construed as computer software fields.

[00:16:05] Speaker 01:
That was ICS's position in the proceedings below.

[00:16:09] Speaker 01:
The board rejected that proposal to construe fields as computer software fields, but they said even if it is computer software fields, this is still patent and eligible subject matter.

[00:16:20] Speaker 01:
It only makes sense that if you're gonna say that the entirety of your invention of fields is just computer software fields, that's by definition generic functionality that's well known.

[00:16:31] Speaker 01:
But elsewhere in their opening brief, on page 26, there's a construction.

[00:16:34] Speaker 01:
There's a statement that says field should be construed to mean data comprised of label data and content data.

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On page 24, field should be further construed as a delimited alphanumeric character string.

[00:16:46] Speaker 01:
Page 46, lexicographic definition of field in the 020 and 609 claims is field M equals label M content.

[00:16:57] Speaker 01:
Given that there are varying positions within one brief, I don't think it's credible to say that one of ordinary skill in the art reading the word fields and the specification would conclude that it's any one of these constructions of the word field, but it's an even simpler analysis than that.

[00:17:12] Speaker 01:
You look at the claims, it just does the word field or data field.

[00:17:16] Speaker 01:
And then you look at the specification and the fields are described generically.

[00:17:20] Speaker 01:
Fields are essentially on a piece of paper when you go into an insurance office and you put down your first name in one box and your last name in another box.

[00:17:27] Speaker 01:
Those are fields.

[00:17:29] Speaker 01:
This alleged invention is about taking the information in those fields and transmitting it within the system.

[00:17:35] Speaker 01:
That's essentially all that ICS claims is their invention here.

[00:17:39] Speaker 01:
That's certainly an abstract concept.

[00:17:41] Speaker 01:
But if we go directly to the 101 analysis,

[00:17:46] Speaker 01:
And we ask ourselves whether under the first step of ALICE, what is the abstract idea that's being pursued by the claims here?

[00:17:54] Speaker 01:
The board found at appendix 29 that the 020 pattern was directed to the idea of transmitting or copying information from a source to a destination.

[00:18:02] Speaker 01:
That's well supported by the specification.

[00:18:05] Speaker 01:
And indeed, we had an expert.

[00:18:07] Speaker 01:
I know that there was a reference here to the Berkheimer decision.

[00:18:10] Speaker 01:
First of all, we don't think Berkheimer applies here.

[00:18:13] Speaker 01:
Berkheimer was on an entirely different

[00:18:16] Speaker 01:
forum and an entirely different posture.

[00:18:18] Speaker 01:
Here, there was an actual hearing.

[00:18:22] Speaker 01:
They had the opportunity to submit an expert report in response to ours.

[00:18:25] Speaker 01:
They didn't.

[00:18:25] Speaker 01:
We have an expert.

[00:18:26] Speaker 01:
We had an interpretation of the specification.

[00:18:28] Speaker 01:
There's substantial evidence supporting the board's findings that the claims are directed to an abstract idea.

[00:18:34] Speaker 01:
The 609 patent the board found at appendix 146 is directed to a process of receiving information, storing it, and determining which parts of it to enter into a display.

[00:18:45] Speaker 01:
But what's most notable is, I think, on page nine of the reply brief, ICS itself says, go to page nine, I'm at the top half of page nine, about four lines down, the claims of the 020 and 609 patent are directed to the management of data.

[00:19:11] Speaker 01:
That is a clear concession that this is directed to an abstract idea, and in fact, ICS has gone

[00:19:16] Speaker 01:
even more abstract than where the board was.

[00:19:18] Speaker 01:
They just say the claims are about management of data.

[00:19:21] Speaker 01:
So there's no question the board's finding with respect to step one of ALICE is supported by substantial evidence, and indeed here on appeal by the appellant's own statements.

[00:19:32] Speaker 01:
Now with respect to the second step of ALICE, neither patent does anything other than claim conventional computer elements like fields, servers, network devices, attachments, and the like.

[00:19:46] Speaker 01:
They're all arranged in a conventional manner.

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And the appellants never below argue that there was any special arrangement or anything special about any of the dependent claims.

[00:19:55] Speaker 01:
Again, just as they're doing here, they said everything rises and falls together.

[00:19:59] Speaker 00:
Your opposing counsel today points to claim six of the 020 reciting quote unquote specialized software.

[00:20:08] Speaker 01:
Right, there's nothing claimed about what makes that software special.

[00:20:11] Speaker 01:
I think it's just a statement that says it's specialized software that's on a server.

[00:20:15] Speaker 01:
I actually think maybe what was trying to be captured in the Claim6 was the server element, but I don't think that there's any dependent or anywhere else in the patent.

[00:20:23] Speaker 01:
The concept of what is covered by a specialized software, there are lots of different descriptions, but one of the descriptions that is in the patent that the board actually relied on was Lotus Notes.

[00:20:38] Speaker 01:
which the patentee acknowledged predates these patents, was a type of software that could be, through which the patent could be implemented.

[00:20:46] Speaker 01:
So it's not specialized software, and it's certainly not specialized software that the patentee actually invented.

[00:20:51] Speaker 00:
They're pointing to- What if it's an inventive software?

[00:20:54] Speaker 00:
I don't think- Would that be an inventive concept?

[00:20:56] Speaker 01:
I don't think so.

[00:20:56] Speaker 01:
I don't think you can, by the words of the patent, just say, I'm claiming something inventive, because that would raise substantial preemption problems, and it would be, I think, sort of a snake eating its tail, right?

[00:21:08] Speaker 01:
I've come up with something inventive, and the only reason I've come up with something inventive is because I've said I've come up with something inventive.

[00:21:13] Speaker 01:
We have tools just to write out what you think is inventive.

[00:21:17] Speaker 01:
You put that into the claim language, and that allows us to compare that to what's well known in the art.

[00:21:22] Speaker 01:
And that wasn't done here.

[00:21:23] Speaker 01:
In here, it was just a reference to specialized software.

[00:21:29] Speaker 01:
In the section 101, on step two of ALICE with respect to section 101, there is a buffer computer argument.

[00:21:37] Speaker 01:
That's new and should be rejected.

[00:21:38] Speaker 01:
That was not raised below.

[00:21:40] Speaker 01:
But even if it's considered, all that we, as far as we can interpret what's being proposed there, is the idea that a buffer computer would just be the use of two different computers to display different types of data.

[00:21:52] Speaker 01:
So in other words, you'd have one computer showing the X-ray and one computer showing

[00:21:59] Speaker 01:
the form that the X-ray pertains to.

[00:22:02] Speaker 01:
I'm not sure because it's not actually claimed, but that seems to be roughly what is being described for the first time here on appeal as a buffer computer.

[00:22:11] Speaker 01:
With respect to the Fields argument, which is also sort of recast as part of the second step of Alice, as I mentioned before, those are new arguments that shouldn't be considered.

[00:22:22] Speaker 01:
They fail on the merits because they're not actually a lexicographer or what this court has established

[00:22:29] Speaker 01:
meaningful definitions in the specification itself.

[00:22:34] Speaker 01:
Field is just directed to nothing specific.

[00:22:36] Speaker 01:
It's just a box on a form or a box on a computer where you can enter data.

[00:22:42] Speaker 01:
And then finally, with respect to the second step of Alice, the patents are merely computerizing a manual process.

[00:22:48] Speaker 01:
What the patents actually talk about is there were well-known ways in the insurance industry

[00:22:54] Speaker 01:
to transmit electronic forms.

[00:22:57] Speaker 01:
If you need a medical procedure, you fill out a form.

[00:23:00] Speaker 01:
It went from your doctor's office to the insurance company for review electronically.

[00:23:04] Speaker 01:
That was well known.

[00:23:05] Speaker 01:
You could mail the x-ray.

[00:23:08] Speaker 01:
That was obviously well known.

[00:23:10] Speaker 01:
What the patents talk about is this results in a hybrid system, which when your x-ray gets to the insurance company, someone has to scan it and associate it with the form.

[00:23:18] Speaker 01:
And the patent says something akin to

[00:23:20] Speaker 01:
The next logical step is the computerization of this manual process, or what they call a hybrid process.

[00:23:25] Speaker 01:
The board's decision calls that out explicitly, but that's exactly what the patent pertains, attempts to do.

[00:23:33] Speaker 01:
And here, in the recitation of what Dr. DiRienzo says, the problem he says he was trying to solve, which is his mother, he sort of tells the story of his mother was going to get dental work.

[00:23:44] Speaker 01:
The dentist said it would take a delay of several weeks.

[00:23:47] Speaker 01:
The explanation was, I have to send her

[00:23:49] Speaker 01:
hard copy x-ray to the insurance company to get approval, and supposedly the light bulb went off with Dr. DiRianzo and said, well, what if we could computerize that and just send it all together?

[00:23:59] Speaker 01:
That's in their brief as their explanation of what it is that Dr., what Dr. DiRianzo's alleged invention was directed to.

[00:24:05] Speaker 01:
I did want to talk briefly about Lech.

[00:24:10] Speaker 01:
They're, you know, each of the arguments that they've

[00:24:16] Speaker 01:
presented with respect to lech in their briefing are essentially irrelevant because, again, all of the patents are invalid under section 101.

[00:24:25] Speaker 01:
So lech is essentially a backup position.

[00:24:28] Speaker 01:
So both patents, all challenge claims are, we believe, not patentable subject matter under section 101.

[00:24:36] Speaker 01:
With respect to the 020 patent, lech anticipates many of the claims, and then lech plus Beezer renders the remaining claims of the 020 obvious.

[00:24:47] Speaker 01:
And that's set out in our chart on page 15, the sort of relationship as to what arguments cover which claims.

[00:24:55] Speaker 01:
But at a high level, the arguments that ICS advances against Lesch fail for at least the following reasons.

[00:25:02] Speaker 01:
First, they rely on the field's argument again.

[00:25:04] Speaker 01:
As we've said, that's a new argument that shouldn't be considered here.

[00:25:08] Speaker 01:
They're essentially just disagreements with the board's reasoning.

[00:25:11] Speaker 01:
This court reviews the board's findings for substantial evidence.

[00:25:16] Speaker 01:
There's no question there's substantial evidence and then finally they're outright mischaracterizations of what Lecce actually discloses.

[00:25:24] Speaker 01:
Thank you, Your Honor.

[00:25:25] Speaker 02:
Thank you very much.

[00:25:28] Speaker 02:
Ms.

[00:25:29] Speaker 02:
Warden.

[00:25:30] Speaker 02:
Thank you, Your Honor.

[00:25:33] Speaker 02:
You have a little over five minutes if you need the time.

[00:25:38] Speaker 03:
I just have a few points.

[00:25:41] Speaker 03:
As Justice Chen pointed out, I think that at a minimum

[00:25:45] Speaker 03:
after our review of claim six if the court does find that the AIC software is specialized and not generic then at a minimum claim six would survive.

[00:25:58] Speaker 00:
Did you separately argue claim six in your blue brief or below?

[00:26:02] Speaker 00:
I didn't see it so I'm asking.

[00:26:07] Speaker 03:
I do not think that we separately argued claim six.

[00:26:11] Speaker 03:
It was just support that we put in for our

[00:26:14] Speaker 03:
Certainly, we argued specialized software.

[00:26:17] Speaker 03:
The fact that we consider the AIC software and the patent itself, as I said, mentions it over 50 times.

[00:26:25] Speaker 03:
It's not something that was available.

[00:26:26] Speaker 00:
Just curious, there's a large family of patents associated with this spec.

[00:26:31] Speaker 00:
Yes.

[00:26:32] Speaker 00:
Are there other lawsuits involving this family of patents out there?

[00:26:38] Speaker 00:
Assume we affirm this today.

[00:26:40] Speaker 00:
Are there other lawsuits with respect to this family?

[00:26:43] Speaker 03:
There is one pending in Dallas that I think would be affected.

[00:26:54] Speaker 03:
It's presently stayed.

[00:26:58] Speaker 00:
Nothing else?

[00:27:02] Speaker 03:
I don't believe so, Your Honor, but if I'm incorrect, I will certainly let you know.

[00:27:07] Speaker 03:
But I do know that there's one in Texas where I think the 609 patent is also involved.

[00:27:15] Speaker 03:
And speaking of the large number of patents in this family, Dr. DiRienzo has obtained newer patents over rejections based on Alice and on art like Beezer and Leck, and as we all know, it's all in the claims.

[00:27:33] Speaker 03:
There's enough technology in this specification to support patents, but due to changes in how claims are interpreted,

[00:27:43] Speaker 03:
in the interim since these issued some claims are going to be invalid and he certainly hopes that others will remain valid and the new ones are all based on this specification.

[00:27:55] Speaker 03:
There's about I think 14 in the family that are based on the original specifications filed in 96 and some are you know straight line continuation some are continuations in part.

[00:28:14] Speaker 03:
I don't think there's much that we need to say about Leck and Beezer because if you find that the software is not generic, then Leck and Beezer fall to the wayside because they clearly do only relate to generic pieces and software.

[00:28:35] Speaker 03:
Mr. Coutry did make one point that I wanted to at least address shortly.

[00:28:39] Speaker 03:
It was about the equation, which they did below as well,

[00:28:44] Speaker 03:
that the fields in the dirianzo patents are indistinguishable, or at least can be equated with the fields on a paper form.

[00:28:56] Speaker 03:
And if I could direct your attention back to column 13, that's appendix 208, starting at line 40.

[00:29:12] Speaker 03:
It will be appreciated that the PAC form, when displayed on the computer screen 212, contains boxes such as those depicted in figure 5A and 5B.

[00:29:26] Speaker 03:
That's where you would enter information.

[00:29:31] Speaker 00:
Those are the data fields?

[00:29:33] Speaker 03:
Those are, no, they are not the data fields.

[00:29:35] Speaker 03:
Those are the boxes on the GUI, Your Honor, but the field is something different.

[00:29:38] Speaker 03:
And let me, if I could, go on because it's explained here.

[00:29:42] Speaker 03:
So the computer screen contains boxes, such as those depicted in figures 5a and 5b, in which alphanumeric characters can be entered so that when the characters are entered in these boxes, they are entered so as to fill a field, in fieldism quotes, a delimited alphanumeric character string.

[00:30:06] Speaker 03:
Being a field, the information denoted by the characters

[00:30:11] Speaker 03:
can be transferred to and used in completing other fields in related documents.

[00:30:16] Speaker 03:
So this is not the same as simply scanning a paper form and then trying to locate information at some point on the form.

[00:30:24] Speaker 03:
These are dynamic fields that can be used elsewhere.

[00:30:31] Speaker 03:
And I guess my last point would be CNC has raised some concern about preemption.

[00:30:40] Speaker 03:
the concern is unjustified because these patents are relatively, maybe even very narrow, because they only address an incompatibility problem between a standard PC and a mainframe computer, or legacy computers.

[00:30:59] Speaker 03:
And that's what they were intended to cover.

[00:31:01] Speaker 03:
That is what they cover.

[00:31:02] Speaker 03:
They don't preempt anything else.

[00:31:04] Speaker 03:
The fact of the matter is, these days, there would be no reason to implement this anymore.

[00:31:09] Speaker 02:
it's only for things legacy systems that existed in the past okay we thank council for the arguments this uh... was the