[00:00:03] Speaker 05:
The United States Court of Appeals for the Federal Circuit is now open and in session.

[00:00:07] Speaker 05:
God save the United States and this honorable court.

[00:00:12] Speaker 02:
Good morning, ladies and gentlemen.

[00:00:17] Speaker 02:
I can't see you nodding this morning, but I know you're there.

[00:00:21] Speaker 02:
We're operating under unusual circumstances, of course, but we're confident you'll be able to make your point.

[00:00:29] Speaker 02:
Our first case this morning is 2019-2308, JST Corporation versus the ITC.

[00:00:37] Speaker 02:
Mr. Massey.

[00:00:39] Speaker 04:
Thank you.

[00:00:40] Speaker 04:
Good morning and may it please the court.

[00:00:42] Speaker 04:
Chief Administrative Law Judge Bullock ruled in favor of JST on both issues presented in this case.

[00:00:49] Speaker 04:
One, the elongated holes or first hole infringement issue, and two, validity, that is, whether the Tyco docking station anticipated the JST patent.

[00:00:59] Speaker 04:
Chief Obolik was right on both issues and the commission committed legal error in reversing him.

[00:01:05] Speaker 04:
On issue one, this is a classic case where preferred embodiments were improperly used to narrow the scope of the claim absent a clear disavowal or restriction of the claim.

[00:01:14] Speaker 04:
The figures are described in the specification as, quote, preferred embodiments and, quote, some embodiments of the present invention, unquote, not as the exclusive way to practice the invention.

[00:01:26] Speaker 04:
That's at Appendix 59, Column 3, Line 44.

[00:01:29] Speaker 04:
Using them to restrict the claim is a cardinal sin of claim construction, as this court said in the Simonette Life Systems case.

[00:01:37] Speaker 04:
And over and over again, this court has repeated that principle.

[00:01:39] Speaker 04:
For example, in the retractable technologies case cited by Chief Ayl, Jay Bullock,

[00:01:44] Speaker 04:
this court said, to disavow claim scope, the specification must contain expressions of manifest exclusion or restriction.

[00:01:59] Speaker 02:
The commission held, and isn't this the issue, that the first hold is closer than any second hold.

[00:02:10] Speaker 02:
And our commissioners have found that the accused does not think that the accused includes second hold closer than any first hold.

[00:02:21] Speaker 02:
Isn't that basically what this case is about?

[00:02:24] Speaker 04:
That is, Your Honor, and I think the language of Claim 2 is what's dispositive, because as I was saying, the Preferred and Monuments can't be used to restrict the patent claims.

[00:02:34] Speaker 04:
The language in Claim 2 simply requires that elongated holes be located, quote, in end regions of the time plate, proximate to two opposite ends.

[00:02:44] Speaker 04:
So the claim doesn't say that the outermost holes must be elongated holes.

[00:02:48] Speaker 04:
It doesn't say that only elongated holes are in the end region.

[00:02:52] Speaker 04:
It doesn't say that elongated holes are at the edges or nearest to the edges or at the outermost holes.

[00:02:59] Speaker 04:
I mean, it uses the term end regions, not edges.

[00:03:02] Speaker 04:
And so that's why we think the Commission erred.

[00:03:05] Speaker 04:
It just ignored the language of the claim and narrowed it according to its construction of the embodiments.

[00:03:11] Speaker 04:
The specification uses the phrase at least to describe the location of the elongated holes.

[00:03:17] Speaker 04:
That's Appendix 58, Column 2, Lines 28 and 48, Appendix 60, Column 5, Lines 3 through 13.

[00:03:26] Speaker 04:
So when you use the phrase at least, you're showing that not all the elongated holes need to be in the end region, and that second holes, or the non-elongated holes, can be located in the end regions as well.

[00:03:38] Speaker 04:
So that... So, Mr. Chair, what do you think the correct construction?

[00:03:41] Speaker 04:
So there must be at least one elongated hole in each end region, and in order to qualify as a first hole, that elongated hole must have a contact leg going through it.

[00:03:53] Speaker 04:
What is the end region?

[00:03:56] Speaker 04:
So the end region is a geographic term.

[00:03:58] Speaker 04:
That's what the Commission acknowledged and was correct.

[00:04:01] Speaker 04:
in Appendix 1758, when it rejected an indefiniteness challenge.

[00:04:07] Speaker 04:
There are illustrations of ends of the time plate.

[00:04:11] Speaker 03:
How do we know what the end, under your construction, how does one know what the end reaches?

[00:04:16] Speaker 03:
How is this defined?

[00:04:18] Speaker 04:
Well, it's defined, it is a geographic term, and I think there was several reasons it's quite definite.

[00:04:26] Speaker 04:
First, the legal construction, you know, we start with the Supreme Court's standard and nautilus, obviously, that absolute precision is not attainable, and that the standard is reasonable certainty.

[00:04:39] Speaker 04:
And so this court has long held that terms of degree are not necessarily indefinite.

[00:04:45] Speaker 04:
In the Nautilus case on remand, for example, the court said that the term spaced relationship in a patent for heart rate monitor passed the reasonable certainty test.

[00:04:54] Speaker 04:
And here you would do as Nautilus instructed, you look to the specification, the prosecution history,

[00:04:59] Speaker 04:
and what the understanding of those skills in the art would think about how to define the term of degree.

[00:05:07] Speaker 04:
And here, for example, the commission's opinion at Appendix 42 was able to label the N regions of the Tyco docking station

[00:05:14] Speaker 04:
The interveners themselves identified the N regions of the Tyco Docking Station at Appendix 6412 and 6413.

[00:05:22] Speaker 04:
Dr. Flowers testified that a person of ordinary skill would be able to make the judgment about whether a hole is in the N region or the center region.

[00:05:31] Speaker 04:
That's Appendix 91, 38 to 39.

[00:05:34] Speaker 04:
And as I mentioned, Figures 1, 5, and 6 in the patent show the ends of the time plate.

[00:05:40] Speaker 04:
That's Appendix 59, Column 3, Lines 22 to 39.

[00:05:43] Speaker 04:
So, and this Court is frequently held, as I said, that geographic terms such as proximate and region

[00:05:51] Speaker 04:
need not contain an exact boundary in order to be definite.

[00:05:54] Speaker 04:
You know, we cite in our briefs to the Mentor Graphics Decision from 2017 that used the word near and said that was not indefinite.

[00:06:02] Speaker 04:
The Athletic Alternatives and Benetton Sports Systems cases used the, decided the term region was not indefinite.

[00:06:10] Speaker 04:
Rosemont in 1984, close proximity is not indefinite.

[00:06:14] Speaker 04:
So all those geographic terms

[00:06:16] Speaker 04:
are sufficient to pass the reasonable certainty test.

[00:06:22] Speaker 04:
And I think one of the lessons of this court's indefinite in this case is that patent terms must be considered in the context of the intrinsic and extrinsic record rather than in abstract or in isolation.

[00:06:33] Speaker 04:
And here, the idea that there must be a bright line boundary defining end region is belied by the fact that a person of ordinary skill would understand that the problem of thermal expansion is a matter of degree.

[00:06:43] Speaker 04:
I mean, although thermal expansion may be most pronounced at the edges, the intervener said it also occurs throughout the entire plate, even to a lesser degree in the center.

[00:06:53] Speaker 04:
That's an appendix.

[00:06:54] Speaker 02:
Yes?

[00:06:55] Speaker 02:
Council, do you want to get to the contact plate issue?

[00:07:01] Speaker 04:
Pardon me, yes, Your Honor.

[00:07:02] Speaker 04:
I'll move to the context next issue.

[00:07:07] Speaker 04:
Yes, that's an excellent way of putting it.

[00:07:12] Speaker 04:
The commission erred in construing contact legs as including the grounding prongs of the Tyco docking station.

[00:07:19] Speaker 04:
Our view is that improperly read the term contact out of the claim, so it would have meant the same had it not just said legs.

[00:07:26] Speaker 04:
And that's the failure to give meaning to every term violates the elementary rules of claim construction.

[00:07:32] Speaker 04:
And here,

[00:07:34] Speaker 04:
Chief A.L.J.

[00:07:35] Speaker 04:
Bullock.

[00:07:36] Speaker 03:
It wouldn't be a doubt if red contact legs is having the purpose of non-electrical conducting legs such as post and mark, right?

[00:07:53] Speaker 04:
Well, exactly.

[00:07:55] Speaker 04:
I mean, the Martin is, I think, is a perfect example.

[00:07:57] Speaker 04:
I mean, claim one was rejected as anticipated by Martin, and so it was amended to replace the term legs with contact legs.

[00:08:06] Speaker 04:
That's the history.

[00:08:06] Speaker 03:
But you said that the claim wouldn't have any meaning if you read contact legs with rounding legs, and I'm suggesting to you that the term contact legs was

[00:08:22] Speaker 03:
kind of post that you are, that would give it meaning, right?

[00:08:27] Speaker 04:
Well, I misspoke if I said the claim wouldn't have any meaning.

[00:08:31] Speaker 04:
The word contact wouldn't be given any meaning under the other side's view, because the leg would mean, as you say, the leg would mean the same thing as a post in Martin.

[00:08:44] Speaker 04:
The post in Martin was a non-contact leg.

[00:08:48] Speaker 03:
It was just like... I'm sorry, I'm not understanding what you're saying.

[00:08:52] Speaker 03:
If you interpret contact legs as the commission did, you mean an electrical connection.

[00:08:57] Speaker 03:
I see what you're saying.

[00:09:08] Speaker 04:
If you interpret it as a grounding prong,

[00:09:11] Speaker 04:
So not a retention leg, not a conductive leg still, but not a contact leg.

[00:09:17] Speaker 04:
Well, then I think we're with Chief ALJ Bullock who said the problem with that interpretation of conducting leg is basically conductive leg rather than contact leg.

[00:09:29] Speaker 04:
is that a person of ordinary skill would recognize the distinction between a contact leg which completes an individual circuit and other kinds of conductive legs like grounding legs which make a common ground, not an individual circuit.

[00:09:42] Speaker 04:
That's what he said in Appendix 3452.

[00:09:45] Speaker 04:
that the grounding prongs may be conductive, but they're all part of the same electrical circuit.

[00:09:51] Speaker 04:
They don't have their own individual circuits.

[00:09:53] Speaker 04:
They share a common ground in contrast to contact legs or contacts which carry each individual signal individually.

[00:10:01] Speaker 04:
And so the specification, for example, refers to a contact

[00:10:05] Speaker 04:
like making a contact with a counterpart connector that's Appendix 59, Column 2, Line 16, Column 3, Lines 56 to 57.

[00:10:16] Speaker 04:
So that would also rule out a contact leg connecting to a common ground.

[00:10:21] Speaker 04:
The specification had in mind a one-to-one connection and an individual circuit.

[00:10:27] Speaker 04:
So we don't think a person of ordinary skill in the art could have understood contact legs in the way the commission did.

[00:10:33] Speaker 04:
And there's also the insulated housing point.

[00:10:35] Speaker 04:
I mean, the claim preamble indicates that to be a contact leg, it must protrude from an insulated housing.

[00:10:41] Speaker 04:
And here, the Tyco docking station legs

[00:10:45] Speaker 04:
are grounding prongs that do not preclude from an insulated housing.

[00:10:49] Speaker 04:
Rather, they're part of a metallic shell that surrounds the housing rather than being part of a contact protruding from the housing.

[00:10:56] Speaker 04:
That's Appendix 6881 and 6890.

[00:11:00] Speaker 04:
So for both of those reasons, the commission's understanding of the grounding prongs was error.

[00:11:07] Speaker 04:
And I do think that the Martin prosecution history that we touched on is also very sportier because the

[00:11:13] Speaker 04:
The post and Martin were, although they were retention legs, they would be the whole process to get to reveal whether the truth of the work of the contact was legitimately inserted in order to interfere with the response of the cameras.

[00:11:32] Speaker 04:
And then, you know, the cameras would actually find one entity that would be classified by the invention and more clearly set forth the intended concept.

[00:11:37] Speaker 00:
Mr. Vannasti?

[00:11:39] Speaker 00:
Yeah.

[00:11:40] Speaker 00:
Judge Shaw here.

[00:11:41] Speaker 00:
Before you run out of time, I just want to ask you one question about the back of moment to the infringement.

[00:11:48] Speaker 00:
Isn't this one significant only embodiment and figure in the show times like other elongated holes?

[00:12:00] Speaker 04:
That is that is true, although the specification said at least so it was implying that not all the elongated holes would need to be in the end region.

[00:12:09] Speaker 04:
But just to take your point that that I think is the the lesson of the intractable of the retractable technologies case the care of technology case.

[00:12:17] Speaker 04:
that we cite in the brief.

[00:12:19] Speaker 04:
There are also several more like Continental Circuits and Philips, Teleflex.

[00:12:23] Speaker 04:
In all those cases, the same point could have been made, that the only embodiments shown in the patent are a certain thing.

[00:12:29] Speaker 04:
And in each of those cases, the court refused to narrow the patent scope to the preferred embodiments.

[00:12:38] Speaker 04:
If there are no more questions, I'd like to save the remainder of my time.

[00:12:41] Speaker 02:
We will do that.

[00:12:44] Speaker 02:
Is this your data set?

[00:12:47] Speaker 05:
All right, you're dying.

[00:12:48] Speaker 05:
That's fine.

[00:12:48] Speaker 02:
You're dying.

[00:12:49] Speaker 02:
Sorry.

[00:12:50] Speaker 02:
And you're putting your time, you're taking how many minutes?

[00:12:53] Speaker 05:
Eight minutes.

[00:12:55] Speaker 02:
Mr. Davis follows you.

[00:12:57] Speaker 02:
Thank you.

[00:12:57] Speaker 02:
Please proceed.

[00:12:59] Speaker 05:
Thank you.

[00:13:00] Speaker 05:
Good morning.

[00:13:01] Speaker 05:
May it please the court?

[00:13:03] Speaker 05:
Here we have a case where on one hand, JST is arguing for a very broad construction with respect to infringement, accusing the Commission of importing limitation,

[00:13:15] Speaker 05:
And then on the other hand, with anticipation, they pretty much want to go 180 degrees the opposite and import limitations themselves.

[00:13:23] Speaker 05:
Both these arguments are unsupported by the intrinsic record and are inconsistent.

[00:13:29] Speaker 05:
With respect to claim construction for infringement, it is clear from the entirety of the intrinsic record, especially the specification here, that the problem to be solved in the prior art is the cracking issue, the cracking

[00:13:44] Speaker 05:
on the end of the time plate at the solder joints of the contact leg.

[00:13:48] Speaker 05:
It is clear in Appendix Pages 58 and 60 in the columns therein that you have to first address this cracking issue of the solder joints of the contact leg at the end of the time plate to prior solve that using interconnected slots at the end.

[00:14:07] Speaker 05:
But this leads to a lot of disadvantages, i.e.

[00:14:10] Speaker 05:
decreased yield

[00:14:11] Speaker 05:
decreased strength and manufacturing issues.

[00:14:15] Speaker 05:
So to expressly solve this issue, the necessary feature is to have holes of elongated shape at the end of the time plate to address this cracking issue of the contact leg of the solder joint.

[00:14:27] Speaker 05:
So you must have that.

[00:14:28] Speaker 05:
That's basically the stone in the pond and the rest are ripples that they argue for.

[00:14:34] Speaker 05:
You have to have that necessary feature of putting at the end of the time plate these holes of elongated shape.

[00:14:42] Speaker 05:
This is consistent with this court's precedent in Tectronic and the law, where we similarly have this criticism of the prior art, this necessary feature distinguishing the prior art.

[00:14:54] Speaker 05:
And you have the full complement of the specification, illustration, embodiment, all illustrating the necessary feature, characterized the invention as the necessary feature, and also supported by the prosecution history here, where again we have

[00:15:11] Speaker 05:
expressly overcoming the marked anticipation by disclosing that you have to have these holes at the end of elongated shape, because you have to have this slight play between the contact legs and the holes of elongated shape to address this issue of thermal expansion.

[00:15:30] Speaker 05:
Now turning to anticipation, NTRC turns to the opposite tack to trying to import limitations that are just simply not supported by the intrinsic record here.

[00:15:39] Speaker 05:
Namely, grounding legs is their creation.

[00:15:43] Speaker 05:
As appears nowhere in the intrinsic record in the specification.

[00:15:47] Speaker 05:
It simply just talks about a polarity of contact, each including a leg inserted through the time plate for contacting the imprinted circuit board.

[00:15:58] Speaker 05:
Makes no distinction about what this contact leg will carry, whether it's signals, whether it's a grounding leg, whether it's a power leg, simply just a contact leg is undisputed

[00:16:09] Speaker 05:
that's what the Tyco connector discloses.

[00:16:12] Speaker 05:
A contact leg, i.e.

[00:16:14] Speaker 05:
a grounding leg in this case, that goes through the time plate connecting to the printed circuit board.

[00:16:22] Speaker 05:
This was agreed to by their own expert with infringement where it appended pages 3151 and 3152.

[00:16:35] Speaker 05:
We're in a question.

[00:16:36] Speaker 05:
So you agree that a contact leg, even under your understanding of the term, can be used in the connection to ground, right?

[00:16:41] Speaker 05:
And they answer, a contact leg can be used to make a connection to ground.

[00:16:44] Speaker 05:
Yes.

[00:16:46] Speaker 05:
Here we have clear that there is no distinction here.

[00:16:48] Speaker 05:
JSC tried to rely on intrinsic evidence here with Martin.

[00:16:53] Speaker 05:
But again, there's no support in its intrinsic record.

[00:16:57] Speaker 05:
There is no special definition that they have for a contact leg.

[00:17:01] Speaker 05:
I mean, indeed,

[00:17:03] Speaker 05:
Their own proposed construction for contact leg is 26 words.

[00:17:06] Speaker 05:
I mean, there's simply no support in the record for the 26-word definition for contact leg.

[00:17:12] Speaker 05:
A leg must complete an individual electrical circuit by connecting to its counterpart connector and thereby making a connection between a female and male electrical connectors.

[00:17:20] Speaker 05:
There's simply no support for this 26-word definition.

[00:17:24] Speaker 05:
What they talk about with the prosecution history, again,

[00:17:29] Speaker 05:
Our case law tells us that we cited three windows.

[00:17:31] Speaker 05:
It has to be an argument made by the applicant to affect claim scope.

[00:17:36] Speaker 05:
This was an examiner amendment, simply a clarifying amendment that went from a flower to contact, each including a leg, a flower to contact, each including a contact leg, also in an unasserted claim.

[00:17:49] Speaker 05:
So it has no bearing on the proper claim scope here.

[00:17:54] Speaker 05:
Accordingly, the commission

[00:17:56] Speaker 05:
Final determination no violation is supported by substantial evidence in accordance with the law, either with non-infringement or anticipation of both.

[00:18:05] Speaker 05:
Thank you.

[00:18:08] Speaker 05:
Was there any other questions from the court?

[00:18:12] Speaker 02:
I don't hear any, so let's hear from Mr. Davies.

[00:18:17] Speaker 01:
May I please report?

[00:18:20] Speaker 01:
The International Trade Commission, as you just heard, got this case exactly right.

[00:18:26] Speaker 01:
They have to be elongated holes at the end, as John has mentioned, because of the plain language and because of the specs.

[00:18:34] Speaker 01:
And our product does not do that.

[00:18:37] Speaker 01:
We have equal dimension holes between the elongated holes at the end.

[00:18:42] Speaker 01:
And that makes sense.

[00:18:45] Speaker 00:
Judge Shaw here.

[00:18:46] Speaker 00:
I have one question, sort of procedural question.

[00:18:49] Speaker 00:
Assume for the moment that we were to agree with you on the issue of infringement.

[00:18:58] Speaker 00:
Is it not the case then that it would not be necessary for us to reach the validity issue?

[00:19:08] Speaker 01:
So, Your Honor, that is correct.

[00:19:10] Speaker 01:
The IPC can be affirmed and should be affirmed on both grounds.

[00:19:14] Speaker 01:
But only one ground, results, as you want to mention.

[00:19:18] Speaker 01:
That would be the end of this dispute.

[00:19:20] Speaker 01:
Okay.

[00:19:21] Speaker 01:
Thank you.

[00:19:21] Speaker 01:
We have two reasons.

[00:19:23] Speaker 01:
But, Your Honor, I don't want to... I'm here for you.

[00:19:27] Speaker 01:
If you don't have questions, I don't want to... So I'm happy to pause because in real life, I would be more capable of judging that.

[00:19:42] Speaker 02:
We're not, Council, we're not going to backstroke and ask some questions.

[00:19:49] Speaker 02:
Please proceed with whatever you have to say, and if you have nothing further to say, that's fine too.

[00:19:56] Speaker 02:
But don't worry about us.

[00:20:00] Speaker 02:
Thank you, Your Honor.

[00:20:01] Speaker 01:
So we've discussed this first issue, and the ICC was right on that.

[00:20:05] Speaker ?:
And they're also right on this second issue that is handed in valid.

[00:20:09] Speaker 01:
When you look at the Tyco connector, it teaches what this pen teaches.

[00:20:17] Speaker 01:
And JST has come up with some arguments, but they do not reflect what this pen teaches.

[00:20:22] Speaker 01:
But the ITC just very ably covered our point.

[00:20:30] Speaker 01:
We are aligned.

[00:20:32] Speaker 01:
We exactly agree with our position.

[00:20:35] Speaker 01:
It's not a case where the intervener

[00:20:38] Speaker 01:
have daylight between what the government is suggesting.

[00:20:41] Speaker 01:
And so I consider my time, the points I need to make this morning, Your Honor, I consider finished.

[00:20:49] Speaker 01:
And so if there are no further questions, I'm happy to sit down.

[00:20:55] Speaker 02:
Thank you, Counsel.

[00:20:56] Speaker 02:
Mr. Massey has some rebuttal time.

[00:21:00] Speaker 04:
Thank you, Your Honor.

[00:21:06] Speaker 04:
The intervenors of the government have taken different views as to what the proper construction of the elongated holes term is.

[00:21:15] Speaker 04:
And the commission has argued that a first hole must be the outermost hole.

[00:21:19] Speaker 04:
And the intervenors have argued that all the first holes must be closer to the edge than any second hole.

[00:21:24] Speaker 04:
I didn't hear anything in their arguments attempting to reconcile their positions.

[00:21:28] Speaker 04:
Both lead to absurdities under the government's view.

[00:21:31] Speaker 04:
Someone could copy our plate exactly, put a single circular hole at each outermost edge and avoid infringement.

[00:21:38] Speaker 04:
Under the intervener's construction, you could put a single elongated hole in the middle and avoid infringement, and both of those positions are absurd.

[00:21:48] Speaker 04:
On some of the arguments that have been made, the government has suggested, the commission has suggested that the problem to be solved here is thermal expansion and that that requires that there be an outermost hole at the edge.

[00:22:01] Speaker 04:
Nothing in the intrinsic or intrinsic record says that elongated holes must be the outermost holes in order for the invention to work.

[00:22:10] Speaker 04:
The commission may know such a finding and the brief asserts this with no citation.

[00:22:16] Speaker 04:
Using your sense of the purpose of a patent is not a proper basis for claim construction.

[00:22:21] Speaker 04:
In the Halmedica case, this court said, the court's task is not to limit claim language to exclude particular devices because they do not serve a perceived purpose of the invention.

[00:22:32] Speaker 04:
On the anticipation argument, is...

[00:22:38] Speaker 03:
which is different about rate or expansion.

[00:22:43] Speaker 04:
That's true, but not all the holes in the end region need to be elongated in order to address thermal expansion.

[00:22:51] Speaker 04:
I mean, so long as at least some of the holes in the end region are elongated, they will provide enough play to accommodate different thermal expansion.

[00:22:58] Speaker 04:
Elongated holes are most necessary for lakes that are larger in size or shorter in length.

[00:23:04] Speaker 04:
and therefore stiffer, those are the legs where the effects of thermal expansion are the greatest.

[00:23:09] Speaker 04:
So I think the interveners are being inconsistent here.

[00:23:13] Speaker 04:
I mean, to say that the only way a time plate can address thermal expansion is by having elongated holes at the outermost edge is inconsistent with the position on infringement, where they say their version of the plate, which also addresses thermal expansion, doesn't infringe because it doesn't have elongated holes at the outermost holes.

[00:23:32] Speaker 04:
On anticipation, we've dealt with their arguments in the brief.

[00:23:36] Speaker 04:
Dr. Flowers did not concede that a contact leg is the same as a grounding leg.

[00:23:42] Speaker 04:
He's specifically testified otherwise, and Judge Bullock agreed with us on that.

[00:23:47] Speaker 04:
That's Appendix 3452.

[00:23:48] Speaker 04:
The prosecution history of Martin on the contact leg point, I think I've recited, at Appendix 201 and 289, it's quite clear that the examiner's amendment

[00:24:01] Speaker 04:
to which the patentee agreed was made to set forth the intended concept.

[00:24:07] Speaker 04:
Thank you very much.

[00:24:08] Speaker 04:
Unless there are no further questions, I'm finished.

[00:24:12] Speaker 02:
Thank you, counsel.

[00:24:14] Speaker 02:
The case is submitted.