[00:00:46] Speaker 03:
Okay, the next argued case, December 19, 1616, CPI card group against multi-packaging solutions.

[00:00:56] Speaker 03:
Mr. Flaherty.

[00:01:08] Speaker 00:
Thank you, Your Honor, and may it please the Court.

[00:01:10] Speaker 00:
CPI seeks reversal of the board's obviousness decision on claims 1 and 18 because there was a fundamental disconnection between the claim language and the analysis that the board undertook.

[00:01:21] Speaker 00:
The clearest instance of that disconnect is where the board in its final written decision effectively substituted the use of selectively found in the prior art and inserted that into step 5 of claim 1 and 18.

[00:01:34] Speaker 02:
But didn't the board actually in one sentence, or a sentence separated by a semicolon, use the word selectively and only together?

[00:01:42] Speaker 00:
They used them in adjacency, Your Honor.

[00:01:44] Speaker 00:
And they did use a semicolon.

[00:01:45] Speaker 00:
But in fact, they almost wrote it.

[00:01:47] Speaker 00:
And the board used the phrase, that is.

[00:01:49] Speaker 00:
So they said selectively, that is, only in a region.

[00:01:53] Speaker 02:
Right.

[00:01:54] Speaker 02:
So they defined selectively to use your word only.

[00:01:57] Speaker 02:
So I don't understand why they're saying they ignored the word only.

[00:02:02] Speaker 00:
Well, they didn't give it any legal weight.

[00:02:04] Speaker 00:
What they did is they found selectively in the prior art, and they effectively read that in to step five.

[00:02:09] Speaker 00:
So they used the word only to engraft the prior art into it.

[00:02:15] Speaker 00:
And so at that point, its obviousness analysis was almost a fait accompli.

[00:02:19] Speaker 04:
Counsel, aside from the particular word used, and I don't mean to demean your argument, but how can it be non-obvious when you've got

[00:02:30] Speaker 04:
when you're securing credit card between two boards, and that's part of the prior art, including sealing it, and so the distinction here is avoiding sealing the actual credit card.

[00:02:48] Speaker 04:
I mean, what is non-obvious about that?

[00:02:51] Speaker 00:
Well, the claim language, Your Honor, respectfully, is a little more precise than that.

[00:02:54] Speaker 00:
So it's not simply enclosing the card inside a package and sealing around it.

[00:02:59] Speaker 00:
The steps have to be read in order to create the claimed secure card space at the end of step five.

[00:03:05] Speaker 00:
So part of it is enclosing the card, but enclosing the card alone, of course, doesn't practice the claimed steps.

[00:03:12] Speaker 02:
Are you saying that the prior art doesn't get you to a secured card space?

[00:03:19] Speaker 00:
The prior art, some of the prior art discloses space that could be called secure.

[00:03:23] Speaker 00:
Other prior art discloses space that wouldn't be secure.

[00:03:26] Speaker 00:
My argument is not exactly what your honor just said.

[00:03:28] Speaker 00:
It's more nuanced.

[00:03:29] Speaker 00:
It's that the particular secured space required by the independent claims of this patent is only made by following these steps in this order.

[00:03:37] Speaker 00:
And the fact that some art may have a different secured space, for instance, a blister pack could be considered a secured space, that would be not the secured space claimed by

[00:03:48] Speaker 00:
claims 118.

[00:03:51] Speaker 02:
What if we ever said that you have to follow everything in a precise order that unless you follow you find every precise order in the prior art that it can't be up.

[00:04:03] Speaker 00:
Oh, maybe I misspoke, Your Honor.

[00:04:05] Speaker 00:
When I talk about the order, I'm talking about the order of steps in this claim rather than the order disclosed in the prior art.

[00:04:12] Speaker 00:
So what I'm saying is, and I hope this is responsive, is that the prior art discloses many spaces, some of which could be considered secure, some of which could not be considered secure, but the claim language of the independent claims in this patent is far narrower.

[00:04:27] Speaker 00:
and goes to its narrowness is not only found in claim five, or excuse me, in step five.

[00:04:33] Speaker 00:
Of course, that limitation is the one under discussion.

[00:04:35] Speaker 00:
But its narrowness is reflected in performing all five claim steps in the order recited in the patent.

[00:04:47] Speaker 00:
I want to address, though, I think the panel's focus is exactly right.

[00:04:51] Speaker 00:
and clearly has understood CPI's argument here is that once, obviousness was a fait accompli once the board holds that selectively and only fundamentally mean the same thing.

[00:05:02] Speaker 00:
This would be a very, this would be a more different appeal than it is if the board had it said the following, which it didn't, if the board had said

[00:05:11] Speaker 00:
We're not sure about the meaning of the word only or the phrase only in a region substantially surrounding an offset from the card and therefore we're going to construe that term or that phrase and engage in a claim construction analysis.

[00:05:22] Speaker 00:
That would be very different and nothing like that occurred here.

[00:05:26] Speaker 00:
What the problem is the board did from the outset what MPS asked it to do in the initial petition to treat the particular claim language as something more general.

[00:05:34] Speaker 00:
that was in the prior art.

[00:05:36] Speaker 00:
And once you do that, the obvious disanalysis flows from it almost automatically.

[00:05:40] Speaker 00:
So the disconnect was there at the beginning.

[00:05:43] Speaker 02:
Is there any example in the prior art where the adhesion went right on the card that was supposed to be in the package?

[00:05:52] Speaker 00:
Yes, so in fact, Willard encourages that, because Willard uses secure in two different senses.

[00:05:57] Speaker 00:
And when Willard is teaching its own invention, Willard discusses the advantage of adhering on the card to the package.

[00:06:05] Speaker 00:
And one of the embodiments in Willard that uses that is when the card swings open to be exposed, you don't want the card falling out.

[00:06:12] Speaker 00:
So there are instances of prior art in this record where you do want.

[00:06:18] Speaker 02:
But even in Willard, that's not

[00:06:20] Speaker 02:
heat sealing portion of what Willard's talking about, right?

[00:06:24] Speaker 00:
Well, Willard says you can use the heat sealing or you can use tape or I think the phrase is any method known in the art.

[00:06:30] Speaker 00:
So the ability and even the desirability of having adhesives on the card is known.

[00:06:35] Speaker 00:
There are other references that I think Your Honor is alluding to.

[00:06:39] Speaker 00:
where there are times where you don't want.

[00:06:41] Speaker 02:
Your expert said there'd be thousands of examples out there.

[00:06:44] Speaker 00:
Yeah, absolutely.

[00:06:45] Speaker 00:
I agree with that, Your Honor.

[00:06:46] Speaker 00:
And so I think that's why it's so important to be faithful to the precise claim language instead of treating it at a higher level of generality to say that, well, we've enclosed a card in a package and put a bonder on it, and that's all that's claimed.

[00:06:59] Speaker 00:
That's, I think, a gross oversimplification of the claims.

[00:07:05] Speaker 00:
But it is illustrative of how the board got to its obviousness findings Selectively is broad and that word can mean different things in the press for a claim construction of the word only did you that is correct?

[00:07:16] Speaker 00:
I think such a construction would have been inappropriate neither party asked for That construction and the board didn't purport to to give an instruction although I think what's under discussion here today is is whether there was some

[00:07:29] Speaker 00:
You know backdoor construction made that the board didn't acknowledge it was doing and that neither party requested I mean to some extent that feels what's going on that a construction if the board wanted to engage in the analysis it performed

[00:07:41] Speaker 00:
it probably had an obligation to do a construction.

[00:07:44] Speaker 00:
Now, that's not the error we've assigned to it here, because both parties agreed a construction was unnecessary, and that's our position today.

[00:07:51] Speaker 00:
The problem was not doing construction, but the problem was, in substance, deviating from the language of the claim, going to the word selectively, which is in the prior and is much broader than the word only as used in the claim.

[00:08:04] Speaker 00:
Selectively, at least as disclosed in MAC, doesn't refer solely to geography.

[00:08:11] Speaker 00:
about where on the panel you apply it, but also temporally, when you create a bond.

[00:08:16] Speaker 00:
In other instances, you can imagine that selectively might go to who or why a bond would be formed.

[00:08:22] Speaker 00:
So once you map on this broad term.

[00:08:24] Speaker 02:
I mean, they only looked at the part of Mac that said you do the heat ceiling where you want to do the bonding.

[00:08:33] Speaker 02:
I mean, why is that not logical?

[00:08:35] Speaker 00:
That phrase in isolation, I'm not going to say is illogical.

[00:08:38] Speaker 00:
In fact, it's almost tautological.

[00:08:42] Speaker 00:
For a heat-activated adhesive, a person will apply heat where they want the bond.

[00:08:46] Speaker 00:
I would submit that's a tautology when we're talking about creating a bond.

[00:08:50] Speaker 00:
The missing link there, though, in the board's analysis was the desire.

[00:08:55] Speaker 00:
Why does one of skill and the art desire to create the bond exactly where step five

[00:09:00] Speaker 00:
asserts, right?

[00:09:01] Speaker 00:
So there, if we want to talk about desirability instead of selectivity, the problem with the analysis is the same, although those two words are different.

[00:09:08] Speaker 00:
So again, selectively and desirably, and where a bond is desired, those are not the same, but the key is that they're different than the word only in step five.

[00:09:18] Speaker 00:
So if there were some reference in the art that the board had relied on to say, here's the reason it's desirable for one of skill in the art to only put the bond where step five of claim one requires.

[00:09:32] Speaker 00:
A reference like that might supply the missing link, so to speak, in what would be needed to sustain the board's analysis.

[00:09:38] Speaker 04:
Council, this application was rejected five times, right?

[00:09:43] Speaker 04:
It was, Your Honor, and I think- What overcame the fifth rejection?

[00:09:48] Speaker 00:
The word only?

[00:09:52] Speaker 00:
The word only was not added prior to the final rejection.

[00:09:55] Speaker 00:
It was added two or three times earlier.

[00:10:00] Speaker 00:
And while the word only was discussed by the applicant, the examiner, in the context we're discussing here with the board's decision, only was not looked through the lens of selectively or where desired the way we're looking through it from the board.

[00:10:12] Speaker 00:
So I think the prosecution history doesn't do a great job of illustrating the distinction between only and selectively because selectively wasn't used that way in prosecution.

[00:10:23] Speaker 00:
With one exception that I think it's important the court understand.

[00:10:26] Speaker 00:
In Willard, paragraph 5 refers to a secured space by applying adhesive around a space in a card, and it cites to figure 4.

[00:10:36] Speaker 00:
Figure 4 from Willard, discussed in paragraph 5, is copied verbatim from the Hansen reference, which was discussed extensively by the examiner.

[00:10:47] Speaker 00:
And so you can compare

[00:10:49] Speaker 00:
Figure four from Willard with Hanson which isn't in an appendix 1258 and you will see that the that Same figure from Willard that where the board cites was lifted verbatim from the Hanson reference Which was discussed extensively in prosecution before and after the word only was added to the claims or any of these key references Willard Mack Jones Jones cited in the prosecution items

[00:11:18] Speaker 00:
time of filing during prosecution your honor at time of filing at time of filing no your honor not the time filing with one and I want to qualify my no answer because the answer is no but as it was explained to the board

[00:11:33] Speaker 00:
large portions of the Willard reference are copied either verbatim or nearly verbatim from the Hanson reference, which was cited during prosecution.

[00:11:41] Speaker 00:
What about Jones?

[00:11:42] Speaker 00:
Jones, I don't believe was cited during prosecution.

[00:11:44] Speaker 00:
No, Your Honor.

[00:11:46] Speaker 00:
The prosecution, the two, the kind of lead references during prosecution, Hanson and Goad, were far more closely related to the claimed invention than Jones, which is a blister pack.

[00:11:57] Speaker 00:
So

[00:11:58] Speaker 00:
Goad and Hanson both were in the card packaging space and of course the blister pack of Jones while the board relied on it is not about cards at all and this is about blister packs rather than two pieces of cardboard.

[00:12:12] Speaker 00:
So to the point about prosecution, I think that the striking similarity between Willard and the Hanson reference in prosecution is somewhat useful.

[00:12:21] Speaker 00:
I think MPS was technically correct when it told the board that the three lead references, Willard, Mack, and Jones, were not cited during prosecution.

[00:12:29] Speaker 00:
I don't deny what my friend across the aisle said in the brief with respect to that point.

[00:12:34] Speaker 00:
But I think it's important in telling that huge swaths of Willard were copied verbatim from Hanson, which was discussed extensively.

[00:12:43] Speaker 00:
While we're on Willard, I think, and Hanson to a lesser extent, the board and Willard, and both experts, but really the board and Willard, use sometimes the phrase secure in two different but very important, importantly different ways.

[00:12:58] Speaker 00:
Secure in the context of this art can mean at least two things.

[00:13:01] Speaker 00:
Willard discloses you secure a card to a panel with an adhesive so it doesn't fall off the panel.

[00:13:07] Speaker 00:
That's not unlike me putting a sticky note on the lectern here.

[00:13:10] Speaker 00:
In some sense, it is secured and it won't fall off.

[00:13:13] Speaker 00:
That use of the word secure is fundamentally different than how this patent claims a secure card package.

[00:13:19] Speaker 00:
In fact, the title of our patent is an ultra-secure card package.

[00:13:23] Speaker 00:
I acknowledge ultra-secure doesn't appear in the claims, but secure as a fix means something different than secure as protect.

[00:13:30] Speaker 00:
And once a person does what the board did and kind of equivocate between selectively and only, and maybe selectively also means where desired, and so these three different words mean three of the same thing, then it's also easy, I think, to be insufficiently precise about secure as a fix,

[00:13:49] Speaker 00:
and secure as protect a card from tampering or theft.

[00:13:52] Speaker 00:
And those senses of secure are not the same.

[00:13:56] Speaker 00:
And I think there may be some dispute about what Willard understood his own invention to be.

[00:14:02] Speaker 00:
But I think when it comes to claim 1 and 18 of the Smith patent, it's completely unambiguous that what's claimed is a secure space.

[00:14:10] Speaker 00:
After you get to the end of all five steps of the independent claims,

[00:14:14] Speaker 00:
It instructs a person of ordinary skill that what's being created is a secure space in that sense of security.

[00:14:19] Speaker 00:
So I think in substance, our chief complaint and the legal error the board made was being insufficiently faithful to the claim language.

[00:14:29] Speaker 00:
If only can mean selectively and then with respect to another piece of art, selectively might also be where desired.

[00:14:35] Speaker 00:
Then in substance, the legal analysis is just cramming the prior art into the claim limitation.

[00:14:41] Speaker 00:
And at that point,

[00:14:42] Speaker 00:
as a legal matter, the obviousness decision is already over, so to speak.

[00:14:50] Speaker 03:
Do you want to save some rebuttal time?

[00:14:54] Speaker 00:
I will save the rest of my time for rebuttal unless the panel has any questions for me.

[00:14:57] Speaker 03:
Okay.

[00:14:57] Speaker 00:
Thank you.

[00:15:07] Speaker 03:
Mr. Rowland.

[00:15:08] Speaker 03:
Good morning.

[00:15:10] Speaker 01:
I'm going to address

[00:15:12] Speaker 01:
Just a couple comments of my colleague at his presentation to start first of all as Regarding Willard and its discussion of adhesive It never says to use heat sealing to attach the card never says what to use heat sealing to attach the card to the panel in fact What it if it says anything about attaching the card?

[00:15:38] Speaker 01:
hard to the panel sticking it, it talks about using something like sticky tape, he said it.

[00:15:45] Speaker 01:
It also talks about using like releasable adhesive, like that little blob of stuff that you often use to peel a card off.

[00:15:51] Speaker 03:
You know what's striking, when you get to the point where you have to combine six references in order to make a case for obviousness, doesn't that raise some sort of inquiry?

[00:16:07] Speaker 03:
as to, I'm looking at claims 20 and 21, were rejected on six references in combination.

[00:16:14] Speaker 01:
Well, Your Honor, I think if you look at the claims and the claim structure, what you see is they simply collected elements and added them together in the dependent claim.

[00:16:24] Speaker 01:
So it's just a miscellaneous collection of various elements.

[00:16:28] Speaker 01:
And so we, this is an art, this is a simple art.

[00:16:32] Speaker 01:
It's making packages.

[00:16:34] Speaker 01:
It's not the art that's often going to be

[00:16:37] Speaker 01:
described in comprehensive way in one particular reference.

[00:16:42] Speaker 01:
So we had to find the references that taught these disparate elements.

[00:16:48] Speaker 01:
And that's why for some of those dependent claims, deep down in the chain, there's multiple references.

[00:16:53] Speaker 01:
For example, one of them talks about poking a hole through the package to hang it on a rack.

[00:16:58] Speaker 01:
Well, that's an obvious thing.

[00:17:01] Speaker 01:
But it may not be talked about in the same

[00:17:03] Speaker 01:
It may not be talked about the same reference where you're talking about heat ceiling for example, so that's why so but for claims For claim one you only needed three references.

[00:17:14] Speaker 01:
We only needed three references and even then mainly the secondary references were really just helping to Elucidate the teachings in Willard so that it would be clear what to to explain so that what will it was talking about

[00:17:30] Speaker 01:
It really just supplemented what we'll describe.

[00:17:33] Speaker 03:
You need the combination.

[00:17:35] Speaker 03:
You need a motivation to combine.

[00:17:37] Speaker 03:
Yes.

[00:17:38] Speaker 03:
You need a suggestion.

[00:17:39] Speaker 03:
And not all of those points seem to have been covered.

[00:17:44] Speaker 01:
The board had eight pages on motivation to combine.

[00:17:49] Speaker 01:
This was extensively discussed for all of the references.

[00:17:55] Speaker 01:
That was in addition to

[00:17:57] Speaker 01:
the discussion of the disclosures of the references themselves.

[00:18:03] Speaker 01:
So I think it was, Your Honor, covered.

[00:18:05] Speaker 01:
This has really not been a point that's been addressed.

[00:18:09] Speaker 01:
The issue here really is whether there was substantial evidence of this limitation that you heat seal around the edge of the packet, which the board had plenty of evidence in front of it.

[00:18:24] Speaker 01:
Willard, the prior art, identified by the expert in terms of its common technique of how heat sealing was done.

[00:18:33] Speaker 01:
Commonly, the expert cited multiple supporting teachings for that.

[00:18:40] Speaker 01:
This was a well-known technique for applying heat sealing in packaging.

[00:18:48] Speaker 01:
In packaging where there's apertures, he explained that.

[00:18:51] Speaker 01:
In packaging where there's blisters,

[00:18:53] Speaker 01:
It just was a very common technique.

[00:18:54] Speaker 01:
There were machines that did this, as he also explained.

[00:18:58] Speaker 04:
So what did the claims add over the prior op?

[00:19:02] Speaker 04:
Just the sealing of avoiding where the credit card is?

[00:19:13] Speaker 01:
The argument that was presented during prosecution, which was discussed earlier,

[00:19:20] Speaker 01:
was whether the paper board that was used for the panels, the cardboard, whether it was coated.

[00:19:28] Speaker 01:
That was what the examiner didn't have evidence of in front of him.

[00:19:32] Speaker 01:
So that was the argument that was made.

[00:19:35] Speaker 01:
And that was the limitation that was added to the claims that the paper board had some coating on it, some non-polymeric coating.

[00:19:43] Speaker 01:
And you can hear that they were trying to distinguish around the prior by putting the word non in it.

[00:19:49] Speaker 01:
And that was the limitation that was at issue.

[00:19:54] Speaker 01:
And so as a consequence, some of the petition focused on the obviousness of using this kind of particular paper board that they claimed.

[00:20:04] Speaker 01:
It was, again, that's not an issue on this appeal, but there was a substantial discussion of that in the record as well.

[00:20:10] Speaker 02:
Do you think there's a patently distinct difference between the word selectively and only?

[00:20:15] Speaker 01:
In this context,

[00:20:18] Speaker 01:
When we're talking about disclosures of sealing around the edge of a package, as was commonly done, the teaching of selectively really has only one conclusion.

[00:20:35] Speaker 01:
And this is why we pointed to MAC.

[00:20:39] Speaker 01:
You are selectively applying heat sealing where you want the seal.

[00:20:44] Speaker 01:
That's what's like.

[00:20:46] Speaker 01:
interpretation that's really provided here.

[00:20:48] Speaker 01:
There's no other explanation that's been put forward.

[00:20:51] Speaker 01:
It's the only conclusion, and it's the obvious conclusion, and the board didn't have to say it was the only, but they had to have substantial evidence for why it would have been obvious to do this, where you're sealing around the edge.

[00:21:02] Speaker 01:
And there was plenty of art to teach like Mack.

[00:21:06] Speaker 01:
Well, the way to do that is to heat and apply pressure only where you want the ceiling.

[00:21:13] Speaker 01:
That's what was in the art.

[00:21:14] Speaker 01:
That's why we pointed to Mack.

[00:21:17] Speaker 01:
And we pointed to Jones to support the obvious teaching from Willard that it was known to seal all around the package.

[00:21:28] Speaker 01:
that is sealed around the edge.

[00:21:30] Speaker 01:
And as the expert for CPI testified, this was thousands of packages.

[00:21:37] Speaker 01:
It's more common than not to do this.

[00:21:39] Speaker 02:
So with respect to the claims that are left before us, there's only the three pieces of prior art at issue, right?

[00:21:45] Speaker 01:
That's correct, Your Honor.

[00:21:47] Speaker 01:
Yeah.

[00:21:47] Speaker 01:
That's correct.

[00:21:48] Speaker 02:
So the Jones and Mack and Willard.

[00:21:50] Speaker 01:
And that's it.

[00:21:53] Speaker 01:
And those teachings are just fully supported, you know, explained by the board and how it reached its conclusion.

[00:22:01] Speaker 01:
And it reached both conclusions.

[00:22:02] Speaker 01:
It reached the conclusion that sealing around the edge was obvious and only around the edge and not on top of the card.

[00:22:12] Speaker 01:
And they reached the obviousness conclusion that you apply heat and pressure only in that sealing region to do that.

[00:22:21] Speaker 01:
That was a known common technique.

[00:22:25] Speaker 01:
The Pellant raised two other issues.

[00:22:33] Speaker 01:
I'm not sure if you have any further questions on that point.

[00:22:36] Speaker 01:
Two other issues on Aperture.

[00:22:39] Speaker 01:
They briefly discussed Aperture.

[00:22:41] Speaker 01:
The Board had substantial evidence saying there was no substantial evidence, but the Board had substantial evidence in front of it.

[00:22:46] Speaker 01:
that the packet had an aperture and through which you could view machine readable data.

[00:22:53] Speaker 01:
There really wasn't even any argument before the board about the machine readable data limitations.

[00:23:01] Speaker 01:
The sole issue was whether it had an aperture.

[00:23:04] Speaker 01:
And this argument that seems to be a claim construction argument that says an aperture can't have a flap on it

[00:23:13] Speaker 01:
really would be inconsistent with the patent itself, the 889 patent itself, which teaches, when it's teaching the aperture, it actually teaches a third panel that can come over and cover the aperture.

[00:23:27] Speaker 01:
That's a column seven in the seven, column seven lines 12, I think through 20, teaches covering the aperture with this third panel, explicitly says that.

[00:23:42] Speaker 01:
This argument that, well, an aperture can't have a cover on it is inconsistent with, as a matter of claim construction, if they were going there, would be inconsistent with the 889 specifications.

[00:23:56] Speaker 01:
And with respect to the final issue, I think, again, there was substantial evidence for the board.

[00:24:04] Speaker 01:
The board discussed the obviousness of using a filament.

[00:24:09] Speaker 01:
It's the same.

[00:24:10] Speaker 01:
It would be used for the same purpose as it was used in the similar type packages, Federal Express packages.

[00:24:16] Speaker 01:
They're flat sealed packages.

[00:24:18] Speaker 01:
You want to open them, you add a filament to make it easier to do that.

[00:24:21] Speaker 01:
That was just an obvious use of the same known technique in the same way.

[00:24:31] Speaker 01:
Thank you.

[00:24:39] Speaker 00:
yours first i want to address the claim my friend across the aisle made about willard and he based he's on card we respectfully disagree completely appendix eleven twenty two paragraph twenty six willard states that the cards

[00:24:53] Speaker 00:
are secured to the package by an adhesive that may be a hot melt at PRF 34.

[00:24:58] Speaker 00:
It says other conventional mechanisms may be used to secure the card to the paneling.

[00:25:02] Speaker 00:
And of course, if we look to MAC for what conventional mechanisms are, it discusses pressure-sensitive adhesives, which it describes permanently tacky at room temperature.

[00:25:11] Speaker 00:
Now the reason I bring up the pressure-sensitive adhesives is we have heat explicit in Willard.

[00:25:17] Speaker 00:
We have cold adhesives explicit in Willard, and we have cold adhesives explicit in MAC.

[00:25:21] Speaker 00:
So it's not correct to say that Willard didn't suggest the use of heat adhesives and or pressure adhesives on the car to secure it to the panel.

[00:25:32] Speaker 00:
Ceiling around the edge, right, so the board discussed at length ceiling around the edge of the package, and again this is one more example of the board being a little imprecise in the claim language.

[00:25:44] Speaker 00:
The claim language requires ceiling only around the perimeter of the card and doesn't refer to ceiling around the edge of the package.

[00:25:50] Speaker 00:
And if those two are not the same, I see that my time is up and we would ask this court to reverse.

[00:25:59] Speaker 03:
Thank you.

[00:25:59] Speaker 03:
Thank you both.

[00:26:01] Speaker 03:
The case is seconded under submission.