[00:00:38] Speaker 04:
Our next case is Deep Green Wireless versus Umar, Inc., 2019-15-70.

[00:00:45] Speaker 01:
Good morning, Your Honors.

[00:00:48] Speaker 04:
Mr. DeVincenzo.

[00:00:50] Speaker 01:
Good morning, Your Honors.

[00:00:53] Speaker 01:
In this action below, the board erred in construing incoming voice signal in the context of a telephone system such that it could encompass a signal that begins on a local device

[00:01:08] Speaker 01:
and is sent outgoing towards a network.

[00:01:13] Speaker 01:
Under the proper construction, the board's finding of obviousness cannot stand.

[00:01:21] Speaker 01:
There's no dispute here that the field of invention is telephone systems.

[00:01:28] Speaker 01:
An incoming voice signal is not a particularly technical phrase.

[00:01:34] Speaker 01:
The common sense meaning of an incoming voice signal

[00:01:37] Speaker 01:
is a signal originating at a network and coming to a local device.

[00:01:42] Speaker 01:
That's what the term means.

[00:01:45] Speaker 01:
The specification repeatedly and consistently uses the term according to its ordinary meaning.

[00:01:53] Speaker 02:
I guess where this term incoming shows up in your claim is in the discrimination circuit limitation, where it talks about incoming voice signals.

[00:02:04] Speaker 02:
Yes.

[00:02:04] Speaker 02:
So as I understand it, the board said,

[00:02:07] Speaker 02:
Well, this means incoming to the discrimination circuit.

[00:02:11] Speaker 02:
There are voice signals incoming to the discrimination circuit that the discrimination circuit detects.

[00:02:19] Speaker 02:
And that's based on the plain language of that limitation.

[00:02:27] Speaker 02:
agnostic as to whether those voice signals are coming from the network or it's coming from anywhere else.

[00:02:36] Speaker 02:
All that matters is that we're talking about voice signals that are coming into the discrimination circuit, that the discrimination circuit will then detect and then

[00:02:46] Speaker 02:
do some discrimination act.

[00:02:49] Speaker 02:
So why is that unreasonable, just based on looking at the language of the claim itself?

[00:02:55] Speaker 01:
Under this court's precedent, we don't just look at the language of the claim itself.

[00:03:01] Speaker 01:
And incoming and outgoing are both used throughout the specification.

[00:03:05] Speaker 01:
And they're used to differentiate between signals originating from the network and signals that are intended to go towards the network.

[00:03:14] Speaker 01:
It's not broadest possible construction.

[00:03:17] Speaker 01:
It's broadest reasonable construction.

[00:03:19] Speaker 01:
And when you have a common sense understanding of a non-technical term like incoming voice signal, and that term is used repeatedly in the specification, only in the manner consistent with its ordinary meaning, and the converse term, outgoing, is only used to describe signals intended for the network in that situation,

[00:03:44] Speaker 01:
A construction that says incoming means incoming to the discrimination circuit, we submit, would be unreasonable.

[00:03:53] Speaker 01:
If we look at the claim and how it's structured, the claim is structured consistent with the specification.

[00:04:02] Speaker 01:
It starts with an apparatus for routing digital data signals.

[00:04:07] Speaker 01:
The first limitation is a network interface component for interfacing with the network.

[00:04:13] Speaker 01:
that must receive digital data signals.

[00:04:17] Speaker 01:
And those signals must comprise at least one voice signal.

[00:04:23] Speaker 01:
The next limitation is the discrimination circuit.

[00:04:26] Speaker 01:
It's connected to the network interface.

[00:04:30] Speaker 01:
It must detect incoming voice signals from among other signals.

[00:04:35] Speaker 01:
Now, the broadest reasonable construction of incoming voice signal, as it appears in that claim, in that order,

[00:04:42] Speaker 01:
is consistent with the spec.

[00:04:44] Speaker 01:
It's consistent with the ordinary understanding of what an incoming voice signal is.

[00:04:51] Speaker 01:
The board's analysis focused solely on the meaning of incoming voice signal with respect to the limitation.

[00:04:58] Speaker 01:
The board never analyzed it with respect to the claim as a whole.

[00:05:03] Speaker 01:
And the board never analyzed it with respect to the specification.

[00:05:09] Speaker 01:
Indeed, with respect to discrimination circuit,

[00:05:12] Speaker 01:
The provisional application puts it in plain English.

[00:05:16] Speaker 01:
It explains that for incoming telephone calls, which we all agree are voice signals, the discrimination circuit will route the telephone line based on the type of call.

[00:05:29] Speaker 01:
What's being routed is the incoming call.

[00:05:32] Speaker 01:
It doesn't become an outgoing call just because it's left the discrimination circuit.

[00:05:38] Speaker 01:
You were referring to the provisional, right?

[00:05:40] Speaker 01:
Yes.

[00:05:42] Speaker 02:
So there's some content in the provisional that's not in the actual written description of this patent?

[00:05:47] Speaker 01:
It is in the written description as well in the description of the discrimination circuit.

[00:05:52] Speaker 01:
The discrimination circuit on column 5, line 7 through 19, also refers to the routing of an above incoming call.

[00:06:02] Speaker 01:
It's just put in plainer English, I'd say, in the provisional.

[00:06:06] Speaker 01:
And it's line 5.

[00:06:07] Speaker 02:
I'm just trying to understand the nature of the relationship between the two specs.

[00:06:12] Speaker 02:
Something happened?

[00:06:13] Speaker 02:
There was a little bit of adjustment?

[00:06:15] Speaker 01:
Yeah, there was a little bit of adjustment, which is fairly common.

[00:06:20] Speaker 01:
There's no in hot verb of support, but it's there.

[00:06:22] Speaker 01:
And for the description and the specification, it's column five, line seven to nine.

[00:06:29] Speaker 01:
And it says, optionally, the invention can be fitted with a discrimination circuit that can detect the type of call and automatically route the communication line to the corresponding DO, which is the various incoming devices on the incoming side.

[00:06:45] Speaker 01:
And then two sentences later, actually,

[00:06:49] Speaker 01:
Yeah, it refers to an embodiment of the invention.

[00:06:52] Speaker 01:
The same devices may be handled, available to handle the above incoming call.

[00:06:59] Speaker 01:
So it's referring to an incoming call being handled by the devices.

[00:07:03] Speaker 01:
UMA argues that no, when a signal leaves the detection circuit, now it's an outgoing call or an outgoing signal.

[00:07:11] Speaker 01:
The specification and no intrinsic evidence

[00:07:14] Speaker 01:
ever refers to incoming or outgoing with respect to the actual discrimination circuit.

[00:07:21] Speaker 01:
In fact, the argument that the discrimination circuit discriminates signals as they are incoming into the circuit and doesn't discriminate signals when they are outgoing from the circuit logically doesn't really follow.

[00:07:39] Speaker 01:
How could the discrimination circuit discriminate signals as they are exiting?

[00:07:44] Speaker 01:
No such circuits described anywhere in the specification.

[00:07:48] Speaker 01:
And the importance of the claim construction decision is that there's no substantial evidence under the proper construction of incoming.

[00:07:59] Speaker 01:
The board did make an alternative finding under the construction proposed by Deep Green.

[00:08:05] Speaker 01:
There, the board said, we find that Gernert, which is the primary reference,

[00:08:12] Speaker 01:
teaches or suggests processing of traffic in each direction and discrimination between voice and data packets in both the incoming and outgoing direction.

[00:08:24] Speaker 01:
The only support the board relied on for that alternative finding was the deposition testimony of Deep Green's expert, Dr. Zavotsky.

[00:08:34] Speaker 01:
That testimony says absolutely nothing about discrimination between voice and data.

[00:08:40] Speaker 02:
But Gernard itself at Column 11 expressly talks about putting a flag in the header so you can identify voice data signals and separate those out from other data signals, right?

[00:08:56] Speaker 01:
You are correct, Your Honor.

[00:08:57] Speaker 01:
But the board did not.

[00:08:59] Speaker 02:
And the point is that is to have more efficient end-to-end transmission of these phone data signals, isn't it?

[00:09:06] Speaker 01:
That's exactly correct.

[00:09:07] Speaker 01:
But there's two problems with that.

[00:09:09] Speaker 01:
One, the board did not rely on it for its alternative finding under the correct construction on page 24.

[00:09:15] Speaker 01:
And it's with good reason.

[00:09:17] Speaker 01:
When you're discriminating for end-to-end communication, you put the discrimination circuit in the beginning while it's outgoing.

[00:09:26] Speaker 01:
not at the end where it's going to be incoming again.

[00:09:30] Speaker 01:
There is no expert testimony that supports placing the discrimination circuit on the incoming side.

[00:09:39] Speaker 01:
The only expert testimony is the testimony of UMA's expert BIMS on A941 to 942.

[00:09:50] Speaker 01:
That is not sufficient testimony that could even support a remand in this case.

[00:09:56] Speaker 01:
It's a list of six potential benefits.

[00:09:59] Speaker 01:
Under the active video case, merely conclusively stating benefits without specifically tying them to the references is not sufficient.

[00:10:09] Speaker 01:
And on A941 and A942, that's exactly what the testimony here does.

[00:10:15] Speaker 01:
And other than the flags, there's no other evidence in the record.

[00:10:20] Speaker 01:
So that's why we respectfully request not just a remand, but a reversal in this case.

[00:10:25] Speaker 01:
There is simply no evidence that could support a motivation to combine in the proper direction.

[00:10:35] Speaker 01:
And unless the court has further questions.

[00:10:40] Speaker 04:
We will save your time.

[00:10:42] Speaker 04:
Thank you, Your Honors.

[00:10:46] Speaker 04:
Mr. Morgan.

[00:10:52] Speaker 03:
May I please the court?

[00:10:53] Speaker 03:
My name is Jeffrey Morgan, and I represent UMA in this matter.

[00:10:57] Speaker 03:
Your Honors, Deep Green's entire appeal depends upon getting its construction of the term incoming to mean incoming from the network instead of what the board applied, which was a plain and ordinary meaning, which means incoming to the discrimination circuit.

[00:11:19] Speaker 03:
This term incoming in Representative Claim 35 only applies in this particular limitation, which reads that a discrimination circuit connected to the network interface for detecting incoming voice signals from among other digital data signals.

[00:11:42] Speaker 03:
The claim limitation itself makes clear that what we are talking about is incoming to the discrimination circuit.

[00:11:48] Speaker 02:
If this court decides that the boards... Why wouldn't you read it as incoming from the network interface, when you look at the claim structure overall?

[00:12:03] Speaker 03:
The board examined that very question, Judge Chen, and determined that it didn't have to do that.

[00:12:10] Speaker 03:
The claims, the name of the game is the claim, and the claim doesn't require

[00:12:16] Speaker 03:
that the signal that is incoming to the discrimination circuit be coming from anywhere in particular.

[00:12:23] Speaker 03:
It certainly could be coming from the network, but it doesn't necessarily have to come to the network.

[00:12:27] Speaker 03:
And I suppose that's an important point for the court to consider here.

[00:12:35] Speaker 00:
Well, it doesn't necessarily have to come from the network, even though the claim language says a discrimination circuit.

[00:12:41] Speaker 00:
connected to the network interface for detecting incoming voice signals.

[00:12:47] Speaker 00:
So it's not just telling you that the signal is incoming to the discrimination circuit, but it's telling you that the discrimination circuit itself is connected to the network for detecting.

[00:13:03] Speaker 00:
So isn't it detecting the signal coming from the network?

[00:13:08] Speaker 03:
Judge Moore, in our view, and I think in the view of the board,

[00:13:11] Speaker 03:
That's certainly a logical and reasonable interpretation, but it's not a required one.

[00:13:18] Speaker 03:
What the board determined and- You learned.

[00:13:20] Speaker 00:
You listened to the last argument, you learned.

[00:13:21] Speaker 00:
Don't tell the judge what she says is unreasonable.

[00:13:24] Speaker 00:
Just tell her that's not the standard.

[00:13:26] Speaker 00:
Go ahead.

[00:13:27] Speaker 03:
Hopefully I can be taught.

[00:13:30] Speaker 03:
The board took a look at this issue as well because Deep Green raised it below.

[00:13:35] Speaker 03:
And Deep Green is saying, well, if signals are coming

[00:13:40] Speaker 03:
into the system from the network interface.

[00:13:43] Speaker 03:
And if the discrimination circuit is connected to the network interface, therefore it must be coming from the network.

[00:13:52] Speaker 03:
Maybe, but not required.

[00:13:54] Speaker 03:
The claims don't require that.

[00:13:55] Speaker 03:
What the claims specifically require

[00:13:57] Speaker 03:
is that the discrimination should be connected to the network interface, not in this particular order.

[00:14:03] Speaker 00:
Not that it's receiving the signal from the network because of that.

[00:14:07] Speaker 00:
It just seems awfully odd to me that the claim would say, I will tell you that I'm in the same boat in this case I was in in the last case, which is no way I would have interpreted this the way the board did.

[00:14:25] Speaker 00:
I'm just trying to figure out if their interpretation rises to the level of being unreasonable.

[00:14:31] Speaker 00:
That's where I am, just flat out.

[00:14:32] Speaker 00:
It's wear everything on my sleeve day, I guess.

[00:14:37] Speaker 00:
So it's hard for me because you may not lose, but the whole spec, every time it does talk about incoming, it's talking about something coming from the network.

[00:14:50] Speaker 00:
And every time it talks about outgoing.

[00:14:52] Speaker 00:
The spec uses these words a lot, incoming and outgoing.

[00:14:55] Speaker 00:
Not necessarily incoming voice signals, but incoming and outgoing do seem to be explaining the direction between the system in a way that's consistent with their interpretation.

[00:15:08] Speaker 00:
So I'm having a tough time.

[00:15:10] Speaker 03:
I understand that, Your Honor.

[00:15:13] Speaker 03:
I suppose I would say two things with respect to that.

[00:15:15] Speaker 03:
First is.

[00:15:19] Speaker 03:
Although the specification describes the flow of traffic in that manner, the claims don't specifically describe it in that manner.

[00:15:29] Speaker 03:
In our view, what Deep Green is attempting to do is attempting to import limitations from the specification into the claim, which is, of course, clearly impermissible.

[00:15:38] Speaker 02:
I guess another thing they arguably are trying to do is translate and replace the word

[00:15:49] Speaker 02:
incoming with the word said.

[00:15:52] Speaker 02:
If the discrimination circuit limitation had referred to said voice signals, now we know that the voice signals being recited in the discrimination circuit are necessarily tethered to the previously referred to voice signals identified in the initial network interface limitation.

[00:16:11] Speaker 02:
Yes, Judge Chen, and that I think is... It doesn't, so it creates a little ambiguity as to

[00:16:17] Speaker 02:
Whether it could be, maybe it still could be.

[00:16:21] Speaker 02:
It doesn't always have to use the word said in order to tether that relationship between the first and second usage of some term like voice signals.

[00:16:33] Speaker 02:
But they didn't say the word said.

[00:16:35] Speaker 03:
Correct.

[00:16:36] Speaker 03:
They didn't, Your Honor, and they could have.

[00:16:37] Speaker 03:
It's the patentee who is in control of the language that they use for their claims.

[00:16:45] Speaker 03:
If Deep Green wanted to make clear that

[00:16:47] Speaker 03:
the signals that are incoming to the discrimination circuit were actually signals that were coming from the network, from the network interface.

[00:16:56] Speaker 03:
It could have said the digital data signals or said digital data signals, and it did not do that.

[00:17:01] Speaker 03:
So therefore, it's not required that a court construe the term incoming to mean incoming from the network.

[00:17:15] Speaker 03:
Even if, however,

[00:17:18] Speaker 03:
this court were to determine that Deep Green's construction of the term incoming is the correct one, and the board somehow failed to appreciate that.

[00:17:28] Speaker 03:
Even still, however, there is substantial evidence in the record to support the board's finding of a motivation to combine the two prior art references, the Gernard and the AT&T reference.

[00:17:44] Speaker 03:
Even if Deep Green gets its way on claim construction, we believe this court still should affirm the final written decision because of the significant substantial evidence.

[00:18:00] Speaker 03:
Both Gernard and AT&T deal with the same type of technology, networks involving

[00:18:12] Speaker 03:
multiple devices containing both voice signals and data signals and routing voice signals and treating voice signals differently than other digital data signals.

[00:18:25] Speaker 03:
Gerner discusses an apparatus for interfacing a wireless local area network with a wide area cellular or public switch network.

[00:18:33] Speaker 03:
AT&T discloses an integrated residence gateway, intelligent services director that connects with a variety of devices including phones,

[00:18:43] Speaker 03:
personal computers, analog and digital devices, and the like.

[00:18:50] Speaker 03:
Gernert, and Deep Green doesn't dispute this, Gernert discloses every limitation in Representative Claim 35, except, they would argue, not the discrimination circuit.

[00:19:06] Speaker 03:
Gernert does, however, disclose a discrimination function

[00:19:10] Speaker 03:
Gernard explicitly discusses how voice packets are flagged with headers indicating that they are voice packets.

[00:19:17] Speaker 03:
In Gernard, the network node examines those packets and treats voice packets differently than other data packets.

[00:19:26] Speaker 03:
And it does so for the purposes of quality of service issues and prioritization of voice over data.

[00:19:34] Speaker 03:
That is exactly

[00:19:36] Speaker 03:
what the AT&T references IRG ISD circuitry does.

[00:19:43] Speaker 03:
And Deepgreen does not argue in front of this court that AT&T does not disclose the discrimination circuit as found in its claims.

[00:19:55] Speaker 03:
So.

[00:19:56] Speaker 00:
Well, would the board found Gernert disclosed discrimination in the incoming direction?

[00:20:00] Speaker 00:
What if I don't think it does?

[00:20:02] Speaker 00:
What if I don't think there's any substantial evidence for that?

[00:20:05] Speaker 00:
Honestly, your expert just said it was bidirectional.

[00:20:10] Speaker 00:
He didn't say it was bidirectional and discriminating in ingoing and outgoing capacity.

[00:20:15] Speaker 00:
So I honestly don't see any evidence for that particular finding.

[00:20:19] Speaker 03:
I don't think this court needs to get that granular in putting themselves in the position of what a person of ordinary skill in the art would understand when reading these two references.

[00:20:35] Speaker 00:
Well, I mean, when you say get that granular, the board made a fact-finding that Gernert discloses discrimination in the incoming direction, and it cited only your expert on the multiplexer disclosed in Gernert being bi-directional, but the problem is, it doesn't, you know, a bi-directional signal is not equivalent to bi-directional discrimination.

[00:20:57] Speaker 00:
It's not the same thing.

[00:20:59] Speaker 00:
And they argue that, and it's just, it's not.

[00:21:04] Speaker 03:
Understand that your honor, but as your honors pointed out.

[00:21:08] Speaker 03:
We are we are here on a substantial evidence standard and during it clearly clearly discloses by Directionality with respect to the flow of traffic it clearly discloses flagging voice packets and treating them differently than other data packets it therefore clearly discloses at least the function of

[00:21:29] Speaker 03:
of discrimination between voice and data.

[00:21:31] Speaker 00:
But that's only in the context of outgoing signals in Garner.

[00:21:34] Speaker 00:
It's never tied to incoming signals.

[00:21:37] Speaker 03:
Given the presence of the multiplexer, demultiplexer, and our expert's testimony, and the board's determination.

[00:21:46] Speaker 00:
But here you have, OK, see, there's just no question to me about what Garner does and doesn't disclose.

[00:21:50] Speaker 00:
It discloses voice packets flagging and treating them differently for outgoing signals.

[00:21:54] Speaker 00:
It discloses bidirectional by virtue of the multiplexer and demultiplexer.

[00:22:01] Speaker 00:
But that's not the same as, that's bidirectional signals.

[00:22:03] Speaker 00:
That's not bidirectional discrimination.

[00:22:06] Speaker 00:
You're trying to get something out of Gernot that is absolutely not there.

[00:22:10] Speaker 03:
And I believe that's why the board rejected our argument below that Gernot actually anticipates.

[00:22:14] Speaker 03:
Because the board agreed with Your Honor that said that, well, Gernot doesn't quite go that far explicitly.

[00:22:21] Speaker 03:
But it does certainly disclose the functionality of discrimination, which when viewed in light of the AT&T reference, which provides the actual circuitry to discriminate

[00:22:36] Speaker 03:
in what Deep Green would say is the incoming from the network direction.

[00:22:41] Speaker 03:
Someone who is trying to solve a person of skill in the art was trying to solve the problems of the patent in suit, which would be to how do we deal with prioritizing voice signals over data signals?

[00:22:54] Speaker 03:
How do we treat them differently?

[00:22:55] Speaker 03:
How do we route them differently?

[00:22:57] Speaker 03:
These two references side by side are almost a perfect overlay.

[00:23:00] Speaker 03:
And given that they are in the same technology area, given that they both deal with high bandwidth environments, given that they both deal with heterogeneous environments, by which I mean a network that has phones and other non-voice devices, like a fax machine or a personal printer or the like or a personal computer,

[00:23:28] Speaker 03:
a person of ordinary skill in the art, taking a look at these two references, there would find a motivation to combine these references to arrive at... You wouldn't create a system to just prioritize phone calls in one direction, you would create a system, a telecommunication system that would prioritize phone calls in both directions.

[00:23:48] Speaker 02:
I'm sorry, Your Honor?

[00:23:50] Speaker 02:
You're saying that the board's opinion is concluding that when you look at these references, you know you want to prioritize phone calls over other data communications.

[00:24:05] Speaker 02:
And the most reasonable outcome would be to do that in both directions, not in just a single direction, as in both incoming and outgoing.

[00:24:17] Speaker 02:
communications, not just one or the other.

[00:24:22] Speaker 03:
I believe that's correct, and I believe that you could do it in both directions.

[00:24:27] Speaker 03:
To the extent that you would only want to do it in the incoming direction, which is what the claim says, incoming to the discrimination circuit, there is certainly ample disclosure and ample evidence in the record, further supported by Dr. Bim's testimony and the two

[00:24:47] Speaker 03:
Gernhardt and AT&T references, why a person of ordinary skill in the art would find that obvious, would use the circuitry of the AT&T reference and use it in combination with the Gernhardt reference.

[00:25:02] Speaker 04:
Anything further?

[00:25:03] Speaker 03:
No, Your Honor.

[00:25:07] Speaker 03:
Thank you very much.

[00:25:08] Speaker 04:
Mr. Defencenzo has some rebuttal time.

[00:25:14] Speaker 04:
Five minutes or so.

[00:25:16] Speaker 01:
Thank you, Your Honor.

[00:25:19] Speaker 01:
First, I'd like to answer a question.

[00:25:22] Speaker 01:
You said if you thought the judgment below was reasonable, you would have to affirm the construction of income.

[00:25:30] Speaker 00:
The claim construction.

[00:25:31] Speaker 00:
I thought the claim construction was reasonable.

[00:25:33] Speaker 01:
Yeah.

[00:25:34] Speaker 01:
I don't believe that's the standard.

[00:25:35] Speaker 01:
I believe it's de novo on claim construction.

[00:25:37] Speaker 01:
So this is different than the last case.

[00:25:40] Speaker 00:
No, this is the broadest reasonable construction.

[00:25:42] Speaker 01:
Oh, OK.

[00:25:43] Speaker 01:
I thought you were saying if you thought the, OK.

[00:25:47] Speaker 01:
But reasonable construction must still be construed in light of the specification.

[00:25:54] Speaker 01:
The construction offered by the board, the board didn't even analyze the specification.

[00:26:00] Speaker 01:
And Council for UMA never suggested the construction was consistent with the specification.

[00:26:07] Speaker 01:
Here, when the specification repeatedly and consistently uses incoming in one manner, that's the most reasonable construction.

[00:26:17] Speaker 01:
And a construction that would allow an outgoing signal intended for the network to be an incoming signal cannot be reasonable.

[00:26:28] Speaker 01:
It is the opposite of the way the term is used in the specification.

[00:26:34] Speaker 01:
And we respectfully think that the specification informs the meaning of the term, and this court's precedent requires the specification to inform the meaning of the term.

[00:26:46] Speaker 01:
Now, on the substantial evidence point, with respect to incoming, the board only relied on Dr. Zabotsky's testimony and nothing else on page 24 of the decision.

[00:27:00] Speaker 01:
That finding, I don't believe you heard UMA's counsel argue that that testimony alone was sufficient to support a finding that Gurnard teaches or suggests discrimination in both directions.

[00:27:16] Speaker 01:
As such, remand at a minimum is required.

[00:27:21] Speaker 01:
Now with respect to the additional evidence, you heard a lot of discussion about pointing to things in Gernard.

[00:27:28] Speaker 01:
What you didn't hear was any expert testimony supporting that.

[00:27:33] Speaker 01:
The only expert testimony in the record is

[00:27:38] Speaker 01:
Dr. Zavocki's statement that Garner teaches communication in both directions, and Dr. Bim's conclusory six benefits of discrimination.

[00:27:49] Speaker 01:
Those benefits are not specific to the references, and they are insufficient to constitute substantial evidence.

[00:27:58] Speaker 01:
Therefore, we respectfully request reversal.

[00:28:01] Speaker 01:
Unless anyone has questions, thank you, Your Honors.

[00:28:03] Speaker 04:
Thank you, Counsel.

[00:28:05] Speaker 04:
The case is submitted.