contention in accordance with the definitions of substantial evidence is that there is not quote such relevant evidence as a reasonable mind might accept as adequate to support the conclusion when the record is considered as a whole the evidence being what the prior  yes yes no expert testimony i'm sorry and also expert testimony explaining what a priority just certainly is a very unusual case the crucial prior art reference is lieberman and she and are explicitly clear as to what they teach but the decision below relying on tyrolean at billy's expert found that they teach quite different and completely foreign to the actual teachings of the references themselves so center of the thought that is the essence of this case under the central evidence review whether written or not the consider the following one lieberman and hsien both teach using an isolation transformer to lieberman and she em all teach that using an isolation capacitive currents can be achieved other than by use of an isolation transformer or the prior art approach of using electrostatic shield for regarding the limitations of claim one of selectively balancing phase and then i phase portions of passive occurrence and see about a wave adjustment circuit for balancing phase and i phase portions of passive or drive the entirety of the decision below his waist petitioner's expert not the actual content of the lieberman reference we now turn to comparing the process of claim one and lieberman  because lieberman and hsien employ an isolation transformer the path of a passive current is not to the substrate was etc instead current flows from the coil to the plasma and then returns to the coil since the current cannot go to ground it must return to the crow oil this is a straight forward application of kershaw's current law which states that current flowing out of any node must equal the current returning to that no the decision apple lease an apple east expert all affirmative li agree that the capacitive currents currents flow from the coil to the substrate chamber was etc and interest in the decision below at one point agrees correctly stating quote according to the two  pages four in five of the decision and i apologize i didn't put down the appendix number continuing on for example from the plasma source to the chamber bodies substrates was etc the upshot is that these find it regarding the processes of claim one and labor and she and irreconcilable with the finding that explanation of what those references teach but i haven't heard exactly how they receive her yet and what exactly except that she was incorrect and that the board should have credited but you know also makes me puzzled as to what i'm supposed to do with that city here on appeal ok i think the key there is the law that substantial evidence is not taken by itself it has definitions that the definition of step stansell error is such relevant evidence as a reasonable mind might accept as adequate to support the conclusion and then in another case when the record is considered as a whole you know our point is that if you look at the actual references you just have to read them and understand that if you have an isolation transformer that goes out into the plaza and then in court or in the kershaw after it come right back into the so i don't think it really makes a difference what the expert had to say you just look at that and it's clear please the court doctor forms for presentation on appeal suffers from the same flaw that it did before the board you have peer on the one side as your honour's alluded to and you have the teachings of the prior art expert testimony about what the prior art discloses that is backed up by additional documentary reference in the form of the other exhibits that lied on and you have the two dollars to one dollar patent itself all of those say one thing and on the other side you have board what dr flamm argued was that if you use an isolation transformer you can't have any reduction in the relevant capacitive currents at all now on appeal and he appears to be arguing and this was not clearly made until his reply brief but i think what he's arguing is that the reduction happens but it's due to isolation not to balancing as the patent claims that simply wrong if you looked at the relevant page of lieberman this is that appendix nine  selective balancing it's describing you use this balance transformer with two inputs it puts two inputs onto the each end of the quote that are opposite in phase they are one hundred and eighty dollars degrees apart from each other in phase doing  this reduces the undesired capacitively coupled r f current flowing from coil to plasma by a factor of two that is exactly what dr graham said and a lot on that's backed up by additional citations that i can give you and that's what the board found configuration that is at nine hundred and twenty two dollars and that is but the pattern expressly claims but even here so it's not relevant what he says here but even if it were it doesn't say anything that is intention with the rest of lieberman no inconsistency between an isolation transformer and a balun the record makes that clear it's two different functions that the transformers forming it is serving as a ballon because it takes an unbalanced input and turns it into a balanced output it's serving as an isolation transformer because within itself it isolates the secondary coil which is the outputs from the primary which is that in its lieberman says this reduces maximum antenna plasma voltage by a factor of two of us also reducing the undesired capacity of current he is not saying that the reduction in undesired capacity of current is coming from isolation and saying it's coming from the use of a balance transformer that is also requirements one is selectively balancing the currents on the coil and the other is using a wave adjustment circuit to do that it says nothing about about reducing let alone a limi teaches that is an advantage of this configuration but it is not claimed so for each of those reasons that the material of their alliance from lieberman simply is not relevant and certainly does not undermine the substantial evidentiary support for the board findings and also like to address the other point that was made about passive couple current going into the plasma and back into the coil and therefore never reaching the substrate there's no  record support for that other than dr flams statement which did not cite anything for that point the references do not say that in fact she on impurity demonstrates that when you use that isolation transformer in a balance mode you get a reduction of capacitive currents capacitive coupling to the substrate and so there obviously is capacitor of current going not just back into the coil but into the the process as well to beg to differ with that first of all if you look at lieberman there's a passage where he defines what a balanced transformer  and he says it is an isolation transformer and we want this language where it says the question can be driven push pull using a balanced tree and it's talking about push pull that comes from the expert transformers it's an isolation transformer an isolation transformer is not the same as a balance a balance is grounded and isolated transformer is not ground and absolutely wrong it can't go to the substrate because it's not grounded it has to go into the plasma and back to the substrate i mean back to the plastic i'm sorry the point still goes frankly when you read the opinion i think what happened is they decided who was going to win and they picked up everything from the expert testimony and they rejected everything from our testimony thank you thank both sides of the cases