[00:00:00] Speaker 03: Enraged gesture, technology partners, 2024, 1585. [00:00:05] Speaker 03: Mr. Wittenselder. [00:00:40] Speaker 02: May it please the court? [00:00:41] Speaker 02: Thank you. [00:00:41] Speaker 02: Good morning. [00:00:42] Speaker 02: This is the second appeal concerning the 924 patent. [00:00:47] Speaker 02: The previous appeal, this court affirmed the PTAP's decision that all the claims are not unpatentable in an IPR proceeding. [00:00:55] Speaker 02: Today, I'd like to focus on two issues. [00:00:57] Speaker 02: First, whether the Lieberman device is handheld, and second, whether the device in Lieberman has two cameras configured as claimed. [00:01:08] Speaker 02: On the first issue, Lieberman discloses two distinct classes of device. [00:01:12] Speaker 02: Figures 5A through 5C of a Lieberman depict what it refers to as the installation. [00:01:20] Speaker 02: For the record, that is Appendix 1252. [00:01:22] Speaker 02: And as depicted and also described in the specification, the installations are very clearly not handheld. [00:01:32] Speaker 02: They're a kiosk, set-top box, or computer implementation. [00:01:36] Speaker 01: The board relied on figure six, right? [00:01:40] Speaker 02: In part, Your Honor, and that's the issue that we see here. [00:01:43] Speaker 02: But that's a later limitation. [00:01:45] Speaker 02: I'm happy to jump to that one, if the court would like. [00:01:48] Speaker 01: For handheld? [00:01:49] Speaker 02: Not for handheld, but that issue, the reliance on that installation comes up with the second issue that I was going to address today. [00:01:58] Speaker 02: I'm happy to jump there now or keep going on handheld. [00:02:02] Speaker 01: OK. [00:02:02] Speaker 01: I was under the impression that the board relied on the figure six version for the handheld. [00:02:10] Speaker 01: Is that wrong? [00:02:12] Speaker 02: The board does. [00:02:14] Speaker 02: But the issue is that later on, when you get to limitations 1E, which requires a second camera, the board in an anticipation argument or anticipation ground [00:02:26] Speaker 02: relies on these separate installation embodiments that are distinctly disclosed and described in specification for anticipation of the second camera, which is contrary to the law on anticipation. [00:02:40] Speaker 02: So I might as well go there. [00:02:43] Speaker 02: The specification first describes those installation embodiments. [00:02:50] Speaker 02: The column 13, and this is appendix 1270 of Lieberman, [00:02:56] Speaker 02: column 13 starting at line four says the Illustrated embodiments all utilize a single video cameras It may be desirable to utilize more than one camera to allow the signing person free movement in his or her environment To track down spatial positions in that environment in such a case the installation of [00:03:20] Speaker 02: should follow the following criteria. [00:03:22] Speaker 02: And then the remainder of that column 13 is describing those distinct installation embodiments before the patent gets to the claims. [00:03:32] Speaker 02: And when we go back to the installation embodiments, they are very clearly not handheld. [00:03:39] Speaker 02: And the law is very clear that for anticipation, every element of the claim invention must be arranged as in the claim. [00:03:49] Speaker 02: Unless a person of ordinary skill in the art would at once envisage the combination, you can't simply combine multiple distinct teachings, which is the case we have here in Lieberman, where they're very clearly broken apart from each other. [00:04:03] Speaker 03: Figure six looks like it can be handheld. [00:04:06] Speaker 02: Sure. [00:04:06] Speaker 02: We will get to that, but because we jumped to the issue of the two cameras, the anticipation ground is clearly contrary to the law because they are [00:04:15] Speaker 02: combining two distinct embodiments within Lieberman to get the second camera in a handheld device. [00:04:23] Speaker 02: And there's no finding that a person of ordinary skill in the art would envisage that combination upon viewing it. [00:04:30] Speaker 02: In addition, the Lieberman is very clear in how it breaks apart those two embodiments. [00:04:35] Speaker 02: Now returning to the issue of the device being handheld. [00:04:40] Speaker 02: There is some disagreement about the construction of the term handheld. [00:04:45] Speaker 02: But I think for the purposes of today, the board's decision is incorrect, even under their own construction. [00:04:52] Speaker 02: The board held that the term handheld means small enough to be used while being held in the hand or hands. [00:05:05] Speaker 02: Lieberman and as Your Honors pointed me to, the board for the handheld issue [00:05:13] Speaker 02: relied on the cellular telephone embodiment of Lieberman, which is figure six. [00:05:23] Speaker 02: Lieberman's cellular telephone is not a handheld device because it cannot be used while being held in the hand or hands for several reasons. [00:05:34] Speaker 02: Again, this is a device for the deaf or hard of hearing. [00:05:37] Speaker 04: Isn't a cellular telephone [00:05:41] Speaker 04: at least comprehend the notion of a phone that can be held in the hand, as the term is used conventionally. [00:05:53] Speaker 04: And that's six. [00:05:55] Speaker 04: Figure six actually calls it out as a cellular telephone device. [00:05:59] Speaker 02: Colloquially, sure, Your Honor. [00:06:01] Speaker 02: I think we do have to keep in mind, however, that this is a divergence from [00:06:08] Speaker 02: what a standard cell phone would be either today or at the time. [00:06:12] Speaker 02: I certainly agree with that. [00:06:13] Speaker 02: But there are reasons that, even though it's described as a cellular telephone, it is not shaped of the size to be used in your hand. [00:06:22] Speaker 04: How do you know that, though? [00:06:23] Speaker 04: And it seems to me that what the board found was that it is capable of being held in the hand. [00:06:32] Speaker 04: And why do you say conclusively that it's not? [00:06:36] Speaker 04: I'm talking about Figure 6, of course. [00:06:38] Speaker 02: Sure. [00:06:38] Speaker 02: So there are several reasons. [00:06:39] Speaker 02: I think, one, the board's decision rested in part on an assumption of dimensions from the figure itself, which is contrary to the law. [00:06:48] Speaker 02: What we can take away from Figure 6 is that it has a flat. [00:06:53] Speaker 04: I'm not sure that that's right as a matter of the law, that you can't draw any conclusions about shape or size from figures. [00:07:04] Speaker 04: The law says, as I understand it, that you can't construe a claim as bound by the parameters set out in a figure, because the drawings can be a little loose. [00:07:18] Speaker 04: But here, for example, one thing that struck me in its argued is that the number pad on Figure 6 is a conventional-looking number pad. [00:07:34] Speaker 04: Typically, they will be in an area that's the size appropriate for using the fingers the way one would in an old-fashioned adding machine. [00:07:44] Speaker 04: If that's true, then this device seems to depict something that would be about the size that could be held in hand. [00:07:51] Speaker 04: Why isn't that a sensible way to read this? [00:07:53] Speaker 02: I think it's a fair assumption, sort of in a vacuum, but we also have to keep in mind that we have a device that has [00:08:02] Speaker 02: a fairly large screen on it to be able to have sign language come back to the deaf or hard of hearing user. [00:08:08] Speaker 02: So that does alter the dimensions from something that we would consider. [00:08:11] Speaker 02: I agree that the numbers would not be sized spaced very far apart, because then it just becomes more. [00:08:17] Speaker 04: Well, we've had cell phones with screens on them. [00:08:20] Speaker 04: I'm not sure that that tells us that this can't be held in. [00:08:26] Speaker 04: The fact that there's a screen doesn't tell us that it can't be held in hand. [00:08:30] Speaker 02: It's not the dispositive issue or item on this figure. [00:08:34] Speaker 02: I think what's maybe more instructive on this figure is simply the configuration of the base of the device relative to the camera. [00:08:44] Speaker 02: And so there's a large discussion both on the record below as well as in briefing about there being a stable base for this. [00:08:52] Speaker 02: The reason being that sign language typically takes two hands. [00:08:57] Speaker 02: And so this device needs to be able to be used during signing. [00:09:03] Speaker 03: Getting back to cameras again, you said Lee Willman discloses one camera. [00:09:08] Speaker 03: Actually, in column 13, it points out that it can be more than one camera, covering a separate angle, operating independently, and avoiding overlap. [00:09:22] Speaker 02: Yes, Your Honor, but then at column 13, line 9, it states that in such a case where there would be multiple cameras, it would be the installation. [00:09:34] Speaker 02: And the installation is how the Lieberman reference refers to the embodiments in figures 5A through 5C, which are, again, a set-top box, a kiosk, or a computer, which are not handheld. [00:09:49] Speaker 02: Returning back to figure 6. [00:09:52] Speaker 02: Configuration between the face and the camera are important and really point to why this device cannot be used in the hand. [00:10:03] Speaker 02: If we look at a regular phone, this device is configured to be used in the hand. [00:10:10] Speaker 02: The camera faces the user. [00:10:12] Speaker 02: It is parallel to the back of the device. [00:10:15] Speaker 02: You hold it like this and use it. [00:10:17] Speaker 02: When we look at Lieberman, the configuration is different. [00:10:21] Speaker 02: Camera 10 is perpendicular to the base. [00:10:25] Speaker 02: That's because, like a laptop, it is designed to be used and is used when sitting on a table, so that the user can have both hands free to use it. [00:10:36] Speaker 02: This device, my laptop, and as a result, the device in Lieberman, cannot be used in the hand. [00:10:43] Speaker 02: If I were to do that here, I'm now taking pictures of my feet, and I can't sign with [00:10:48] Speaker 03: One of the grounds for rejection is obviousness as well as anticipation. [00:10:55] Speaker 02: Correct, Your Honor. [00:10:56] Speaker 03: So the reference doesn't have to be precisely on point. [00:10:59] Speaker 02: Correct, Your Honor. [00:11:00] Speaker 02: Our position is that the anticipation, neither ground is correct. [00:11:06] Speaker 02: Anticipation, surely, because you are not permitted, given the distinct disclosure of embodiments, to reach between the embodiments. [00:11:14] Speaker 02: I think the issue that we brought up. [00:11:16] Speaker 04: One argument that's made by the appellee here is that with respect to the argument as to the embodiment, the different embodiments, that you didn't make that argument before the board and that you've therefore waived it. [00:11:35] Speaker 04: What do you say to that? [00:11:37] Speaker 02: I think we addressed this in our reply on the actual screenshot [00:11:43] Speaker 02: the argument itself. [00:12:00] Speaker 04: You can come back to it if you like. [00:12:02] Speaker 02: Thank you, Your Honor. [00:12:04] Speaker 02: But there was a series of similar claims in the response brief. [00:12:10] Speaker 02: And I'll have the pages in my rebuttal. [00:12:14] Speaker 02: But they were addressed. [00:12:15] Speaker 02: And we pointed the court to each of those instances where there was a supposed waiver. [00:12:20] Speaker 02: But we actually expressly had the language from the record below where we presented these arguments. [00:12:24] Speaker 02: Well, no. [00:12:24] Speaker 04: Yeah, sometimes. [00:12:26] Speaker 04: There are a couple of them that I had questions about. [00:12:29] Speaker 04: But go ahead. [00:12:31] Speaker 02: But as to the obviousness issue, I think one of the overlying issues with the opinion [00:12:38] Speaker 02: is that it seemed to just go from anticipation and rubber stamp a bit the obviousness finding simply that because the embodiments were in the reference that it was inherent. [00:12:49] Speaker 02: Inherent is probably the wrong word, but that it was obvious because there were these two distinct embodiments in Lieberman. [00:12:58] Speaker 02: But there's simply no analysis or finding as to why a person of ordinary skill in the art would make that jump to combine the two distinct references. [00:13:08] Speaker 03: In particular, Council, you're into your rebuttal time. [00:13:11] Speaker 03: I assume you want to save it. [00:13:14] Speaker 03: You can continue if you like. [00:13:16] Speaker 02: Thank you, Your Honor. [00:13:16] Speaker 02: I can just finish my thought. [00:13:18] Speaker 02: I think it's particularly important to keep in mind the time frame of this, where it wouldn't necessarily have been obvious to take what was a installation configuration, a large device, and somehow just obviously shrink this down into the small handheld device. [00:13:36] Speaker 02: That's all I have, and I'll save the rest of my time unless Your Honors have any further questions for me. [00:13:42] Speaker 03: We will save it for you. [00:14:01] Speaker 00: Good morning, Your Honors, and may it please the Court. [00:14:02] Speaker 00: Justin Bova for the Director of the USPTO. [00:14:06] Speaker 00: I heard counsel only discuss three of the issues that they raised in their briefing, so I'll address those and rest on the briefing for the rest of it. [00:14:14] Speaker 00: With respect first to the installation argument that we pointed out in our brief at page 39, that argument was not made below with respect to what an installation is. [00:14:24] Speaker 00: And so that is forfeited. [00:14:28] Speaker 04: Well, they say that they responded to that in their reply, which I don't have the page. [00:14:33] Speaker 04: I know that there was something in the reply that I don't have the particular page. [00:14:37] Speaker 04: Do you have anything to say about what they say in the reply? [00:14:43] Speaker 00: I don't actually think on that particular issue that there was, that was raised below on the installation portion. [00:14:50] Speaker 04: There was nothing in the reply about installation. [00:14:54] Speaker 04: I had thought there was, but I may have been mixed up with another issue. [00:15:00] Speaker 04: Because there were several points that you raised, waiver, and they responded to some of them, at least. [00:15:06] Speaker 04: I had thought that was one of them, but I may be wrong. [00:15:10] Speaker 04: I don't want to use up your time. [00:15:12] Speaker 00: It may not be there. [00:15:14] Speaker 00: I don't think it was for this particular issue. [00:15:17] Speaker 00: But even so, on the merits, in Lieberman at column 13 at appendix 1269 or 1270, as Gesture read from that column lines 4, the illustrated embodiments all utilize single video cameras. [00:15:41] Speaker 00: That's discussing all of the embodiments in the patent in this reference. [00:15:45] Speaker 04: So you're reading illustrated embodiments as including all embodiments in the patent, not simply those being discussed at that point in the patent? [00:15:54] Speaker 00: All of the embodiments that are discussed, which includes Figure 6, which is that cellular telephone version in Lieberman. [00:16:00] Speaker 04: OK. [00:16:01] Speaker 00: So the illustrated embodiments all utilize a single video camera, just like Figure 6 does. [00:16:06] Speaker 00: And then it goes on to say it may be desirable to include a second camera. [00:16:10] Speaker 00: Now, this discussion of on line nine, in such case, the installation should follow. [00:16:14] Speaker 00: That was not made below so that there's no finding about what this reference means from the board. [00:16:19] Speaker 00: But a fair reading of that also is that the installation of a second camera should follow these parameters. [00:16:27] Speaker 01: Well, is the term installation used at any other point in this specification? [00:16:34] Speaker 00: Yes, it is, Your Honor. [00:16:35] Speaker 01: In describing in the brief description of the drawings, right? [00:16:40] Speaker 00: In the brief description of the drawings, when it talks about figures five, yes, that's what- The figure five embodiments, they're described as installations. [00:16:50] Speaker 01: That's right, Your Honor. [00:16:51] Speaker 01: And then the brief description of the drawings, figure six, doesn't reference that embodiment of being an installation. [00:16:57] Speaker 00: That's right, Your Honor, yes. [00:16:58] Speaker 01: But it also- I guess the argument they're trying to make is that raises an inference here that when it says installation at column 13, [00:17:10] Speaker 01: It's referencing previously mentioned installations, which would only be the figure five illustrations and not figure six. [00:17:21] Speaker 00: That is a possibility that it was being that precise for that term. [00:17:26] Speaker 00: But I think a fairer reading in the context of this is preceding that statement, it says the illustrated embodiments all utilize. [00:17:33] Speaker 00: It would make little sense that it would say, well, we're not talking about the figure six embodiment when we're talking about including the second camera. [00:17:40] Speaker 00: So the installation, I think a fair reading of that actually is the process of installing the second camera. [00:17:46] Speaker 00: There is, as Judge Laurie pointed out, also an obviousness ground for including a second camera that the examiner found and the board affirmed. [00:17:55] Speaker 01: Are there any other usages of the term installation other than the two we just discussed? [00:18:01] Speaker 00: I believe it's discussed only in the context of this, column 13, and for figure five. [00:18:10] Speaker 00: It's not used often, and it's not used, I don't think, as precisely as gesture would have it. [00:18:17] Speaker 00: It's used here, again, I think a fair reading is to include it as a reason for how to install the camera itself, the second camera itself. [00:18:27] Speaker 04: Going back to the basic point that was raised by your present counsel, that you can't take something from one embodiment in a patent and combine it with something in another embodiment in a patent for purposes of anticipation. [00:18:44] Speaker 04: What do you say to that proposition? [00:18:47] Speaker 00: Well, if Your Honors agree with me that this is a general teaching, [00:18:52] Speaker 04: No, let's assume it's not. [00:18:54] Speaker 04: Let's assume it's limited. [00:18:56] Speaker 04: But can you borrow elements from different embodiments for purposes of anticipation in a prior? [00:19:03] Speaker 00: I think if it's very specific to one embodiment and very specific to another embodiment, no, you would not be combining them for anticipation. [00:19:10] Speaker 00: But again, then it has a fallback of that the board needs to combine. [00:19:13] Speaker 04: Obviousness would be the fallback at that point. [00:19:14] Speaker 04: Single reference obviousness? [00:19:16] Speaker 00: Single reference obviousness, yes. [00:19:18] Speaker 00: And then Sears, as a secondary reference, also teaches multiple cameras. [00:19:22] Speaker 00: But the board and the examiner relied on Lieberman, this reference, as obvious to include a second camera, with the rationale that they provided of making it more desirable and more useful for a user. [00:19:37] Speaker 00: I also heard Gesture argue about handheld. [00:19:41] Speaker 00: And I didn't hear them argue for their claim construction. [00:19:44] Speaker 00: So assuming that the board's construction is correct, [00:19:47] Speaker 00: that handheld means is a size requirement that the device is small enough to be used while being held in the hand or hands, which is consistent with what Gesture argued below in their briefing. [00:20:02] Speaker 00: Lieberman's device, as Your Honor's recognized, there's nothing to, or as Gesture acknowledged, a fair assumption that this device in Lieberman is handheld. [00:20:12] Speaker 00: Based also on the size of the keypad, that it gives you context, [00:20:17] Speaker 00: The board didn't rely on Figure 6 to say these are specific dimensions and specific measurements that show this is handheld. [00:20:25] Speaker 00: They showed Figure 6 called the cellular telephone version and said that this too is capable of being held while being used. [00:20:34] Speaker 00: There's also no requirement that it be held while being used. [00:20:38] Speaker 00: That's only under their construction. [00:20:40] Speaker 04: Is there anything in the record that would suggest that in 1999 the term cellular telephone was understood to mean handheld device? [00:20:53] Speaker 00: There's nothing there's nothing in the record beyond Lieberman itself here. [00:20:57] Speaker 00: That's what the board relied on. [00:20:58] Speaker 00: The board said well prior art also says [00:21:02] Speaker 00: The prior art also shows a cellular telephone device that is in Lieberman. [00:21:07] Speaker 00: That is a handheld device, just like any other device that's common. [00:21:11] Speaker 04: What reference is that? [00:21:13] Speaker 00: Lieberman. [00:21:14] Speaker 04: Where in Lieberman do you say? [00:21:17] Speaker 00: Oh, figure six, cellular telephone. [00:21:18] Speaker 04: Oh, so you're going back to figure six. [00:21:20] Speaker 04: So figure six says this is a cellular telephone type device. [00:21:25] Speaker 04: But what it doesn't say, unless we assume [00:21:28] Speaker 04: already the conclusion that Figure 6 shows a handheld device, it doesn't say that cellular telephones are necessarily handheld. [00:21:36] Speaker 04: That's what I'm looking for. [00:21:37] Speaker 04: Is there anything anywhere in the record that would suggest that that was an understanding of the meaning of cellular telephone at the time? [00:21:47] Speaker 00: There's no general teaching that cell phone is something that was handheld. [00:21:51] Speaker 00: Although I don't know that since the invention of the cell phone, there has been a cell phone that is not handheld. [00:21:56] Speaker 04: I was going to say, I certainly am. [00:21:58] Speaker 04: I was aware of the very early versions of cell phones, which were cumbersome, but still handheld. [00:22:07] Speaker 00: That's exactly right, Your Honor. [00:22:08] Speaker 01: I guess there's nothing in the record of an example of a cellular telephone that is some monstrously large object that cannot be held in one hand. [00:22:17] Speaker 00: That's exactly right, Your Honor. [00:22:18] Speaker 00: Yeah, there's no evidence that it cannot, of a cell phone that cannot be held in the hand. [00:22:23] Speaker 00: There is evidence in Lieberman itself again at column five that talks about its portability and transportability and able to move through the wireless network. [00:22:32] Speaker 00: This is at appendix 1266, column five onto column six, so that it can be transported, maybe transported and communicate as a wireless remote, which gives further context that this is something that is in fact handheld. [00:22:46] Speaker 04: But portable doesn't get you there, right? [00:22:48] Speaker 04: Because a laptop is portable, but you wouldn't call it handheld, even though you could hold it in two hands easily and in one hand with some difficulty. [00:22:58] Speaker 00: Yes. [00:22:58] Speaker 00: A lot of things in the vacuum, maybe, but in the context of cellular telephone version in Figure 6, discussed as transported and can communicate as a wireless remote. [00:23:08] Speaker 00: All of this suggests that this is a smaller device than something as a laptop that would be used or that could be portable and yet not necessarily handheld. [00:23:20] Speaker 00: I did hear a little bit discussion about the obviousness issue and there was commentary that there's no findings about why one would substitute the [00:23:32] Speaker 00: the onboard processor into Lieberman, but there were findings that the examiner made. [00:23:39] Speaker 00: For example, at appendix 950 to 952, the examiner found that this would be a, these are known equivalents, well-known equivalents in the ARC for onboard and off-board processors. [00:24:01] Speaker 00: that you could substitute the one that's disclosed in Sears onto the one in Lieberman with predictable results. [00:24:08] Speaker 00: In part, the examiner relied on the about declaration that was part of the ex parte three exam request. [00:24:14] Speaker 00: And that declaration itself was never contested or challenged. [00:24:18] Speaker 00: So there is substantial evidence to support the board's finding that this is a simple substitution of art known equivalents with predictable results. [00:24:27] Speaker 00: Unless your honors have any other questions [00:24:29] Speaker 01: Are there any other re-exams or IPRs with gesture patents lurking in the PTO? [00:24:37] Speaker 01: Or are we at the end? [00:24:39] Speaker 00: There's one after this argument. [00:24:41] Speaker 00: I know that. [00:24:44] Speaker 00: You're very honest. [00:24:44] Speaker 01: Thank you. [00:24:46] Speaker 00: I don't know of any others, Your Honor. [00:24:49] Speaker 00: Maybe Mr. Wittenzellner knows. [00:24:51] Speaker 00: He did also discuss the previous decision about this particular patent, and that was decided earlier this year, June 5, 2025, at 2025 Westlaw 158-4286. [00:25:06] Speaker 00: And Gesture argued that this court affirmed the board's finding that it was not unpatentable, but actually what this court did was affirm the board's finding that [00:25:19] Speaker 00: Apple failed to show a prior reference that's not at issue here was non-analogous art, or was analogous art. [00:25:26] Speaker 00: So there was a failure of proof at the analogous art stage. [00:25:30] Speaker 00: The board did not affirm unpatentability on the merits. [00:25:36] Speaker 03: Thank you, Mr. Dover. [00:25:39] Speaker 03: Mr. Wittenzellner has a little rebuttal time. [00:25:49] Speaker 02: Thank you. [00:25:52] Speaker 02: I'd like to address two points that my counterpart raised. [00:26:21] Speaker 02: I believe it's pages 14 through 15 of the apply brief, but I'll double check that. [00:26:26] Speaker 01: I wanted to... A1117 to 1118? [00:26:33] Speaker 01: Is that right? [00:26:37] Speaker 03: Right. [00:26:40] Speaker 01: Oh, I thought the question was whether this argument was raised below in front of the board. [00:26:44] Speaker 01: This question about installation, what does that mean? [00:26:50] Speaker 01: Did you argue that issue before the board? [00:26:53] Speaker 02: I don't know that the term installation itself came up. [00:26:56] Speaker 02: But I believe we argued about the fact that there are no embodiments of two cameras within the handheld embodiment. [00:27:05] Speaker 02: I don't know if we use the term installation itself. [00:27:10] Speaker 02: Limits of trying to search. [00:27:13] Speaker 02: But quickly, to respond to my counterpart's discussion of the term installation, [00:27:18] Speaker 02: I think the specification in Lieberman is very clear. [00:27:21] Speaker 02: The installation embodiments are something you would install somewhere. [00:27:25] Speaker 02: They are fixed. [00:27:27] Speaker 02: They don't move, unlike Figure 6, which is the cellular telephone embodiment, which is portable. [00:27:33] Speaker 02: It is not installed somewhere. [00:27:35] Speaker 02: It is carried with you so that you can use it in different locations. [00:27:40] Speaker 02: The other point is my counterpart raised the issue with respect to moving processors from a distributed architecture into one device. [00:27:49] Speaker 02: I did not raise that in my argument. [00:27:51] Speaker 02: What I was referring to is the fact that the opinion from the board does not contain any reasoning for why a person of ordinary skill in the art in this single reference [00:28:02] Speaker 02: obviousness rejection would look and combine, take the two cameras from these large installation embodiments and then move that into the single camera embodiment in Figure 6. [00:28:17] Speaker 03: Thank you, counsel. [00:28:17] Speaker 03: I think we have your argument. [00:28:20] Speaker 03: Case is submitted.