now the issue is well briefed so in one issue it's well briefed so the short today i just want to talk quickly about figure two and it's disclosures and then address two of the more central argument of the first as you know that for a tenant that is directed to romer's in a visiting network in the example we give in our brief we have a lawyer from germany trying to call the european patent office here in washington d c and she's using the figure two which requires any communication other than the transfer of information back and forth figure one has a strong network right figure one shows an environment where the in the intelligence gateway is connected as an option for what it calls a packet switching network we would commonly call it the internet today which is different from the network that is otherwise the colors of the why is it correct it's an option can we assume that just the term against weight that we're talking about two distinct networks yes the gateway does work as a translator between two networks it would particularly to network dialing sequence the visited network with understand that it's deeply function and that's how it's working there is no requirement as you can see the feature to that it also exchange information with some other external network i'd never guess i get it you're right intelligent gateway as illustrated in figure two now let me repeat that because it's slightly confusing without the point about figure one there is nothing in the specification it says bigger one is a single system and has to have all those components specification expressly says that figure one is in illustration of some environment of the president engine so when you look at figure one you see multiple versions of the components that are necessary for the invention one optional component is a connection to the external network it's optional it's said is optional and there is nothing require where there is a will certainly if you look at  it's not required and one skilled in the art understanding this call flow with know that a connection to the external internet is not required and i submit your honor that the defendants conceded that in their opposition they say figure two shows the essential connections in components necessary for that call flow and that's the translation of dialing  claimed ten inclines forty are repeats cover exactly the embodiment we see in figure two and there's nothing about those claims that require any connection to an external network you can perform its gateway functions by simply communicating back and forth with the mobile switch network i guess i'm having a little trouble understanding the sentence a column for let me just tell you when i read it how i understood it need to really know why i'm wrong with it says the p l m a n thirty may be coupled to a global packet switch network twenty two via a visited intelligent gateway i guess i didn't understand that sentence to suggest that there w it's talking back and forth to the mobile switch network and then the mobile switch network yawn and third then connect with a color top international telephone now you also have shown a home network now let me be and where we began we talked about a gateway being between two networks two networks here is the roamers network and the roamer from a home network and the visited network and as twenty or reserve the rest of my time for paris thank you judge more minutes please the court my friend agreed that it gateway connects two networks together this is a term of art in network communication hundred forty six times in the stat and we know what a person of skill in the art understood a gateway to mean at the time because the technical treatise is that this court has relied on over and over again tell us the connection between two networks translating not dialing sequences as mr david l said but network protocols linking for example circuits which network to a packet switch network or two different kinds of networks a wireless network to a wired network a gateway which is claimed in the system claims and the apparatus claims is a specific term that is known to network engineers network architects to require an expert on that work the claims and specification are absolutely c optionally do something calling for line forty five optionally may do something they had sort of the additional word optional when they wanted an option may indicate only that the global packet switch network twenty two is an example of a defendants and said that the connection may be direct or indirect so even figure two shows an action of two networks moreover the patent discloses a specific third kind of network a virtual private network that is a corporate network for example this court may have a virtual private network for the judges and their staff to use an intelligent gateway could connect directly between the mobile network the v p element and and third unit in nature to fatten and a virtual private network and that's all disclosed in one of the embodiments in the specification just more figure true is not a standalone bodman it is a view in the language of the regulations one point eight one of the system claim which is depicted in figure one is the court knows the drawings must disclose electrons went through to perform a particular function that's all a cough cough oil and you can tell that if you look at the regulations one point one says the patentee may not use arrows in the drawings except to indicate the direction of information flow  to that to the to the west to the international telephone network i mean eventually gets there but the point of novelty in the invention is as for next in between two and three there are two says wait for and telephone you translate those telephone numbers using database thirty one which is inside that box database thirty one which is also disclosed in the patent listed in figure one as well database thirty one at the patent cells invention is here is that box no it was all the codes in the home network how does it know those codes because it's updated on a regular basis using the internet as the invention so that even this single call flow is not calling up the internet because that excluded by these claims but it has to be updated from an external network or system in the language that that term a specification and in fact your honor has a very interesting point this pat this is mr di matteo's entire argument because a figure to the v p element that is the room that the biz it is network the left hand network does not have to be connected to an external network right that's his entire argument the pen actually discusses that point three one example of that is in column five lines thirteen through ninety where it says that the visiting of the roemer is on a network which is not connected to global packets which network twenty two twenty two does it say then there's a visited intelligent gateway in that system not in that environment there is an optional to make it work a country intelligence gateway on the right hand side disclosed it at line fifteen because you still have to have  signaling transfer point coupling the external network to an external signaling network so again that external network is part of the interface of the moville it approaches the same thing as the any external network again to be clear the packet switch network is shown as an example and is listed in claim one but the but the pad is not listed to the internet it could be used for example to connect directly to a v p n in the old days  this is an older patent hotel larger tell or even this courtney wants of had a private branch exchange system a p b x system which would be a dedicated phone system circuits which just them this invention very easily the v a g the internet intelligent gateway everything on the right hand side simply because that call flow doesn't go through those components in that particular disclosed high profile flow which is not to say that they're not part of the system claimed in the patent because some of them functions that can be performed by intelligent gateway and for that one function these are the only components that would have been needed so it doesn't tell me all of the others to me it's all the other functions that must perform to complete that single call and in particular doesn't disclose the updating function which has to happen at some point if there were any doubt about this what the gateway means and again gateway is there is no network engineer in the  record where the application was initially rejected over a prior art patent that showed an s c p a service control point which is similar to the s t p a signal transfer point in the disclosure here and the applicant star home responded quote as a twenty one a gateway provides access to an extra no environment it is defined in that way and it provides a page in line number that is identical to the language of the specification in the united states that is in terms of an access means from one network to another so the entire argument to bring it back to where we started the court's judgment has to be affirmed unless an intelligent gateway  network and it goes on disclaimed in mind one is closed in the in the course on a christmas vacation is using global packets with network twenty to the internet for those two intelligent gateways to talk to each other that is what that that refers to claim ten started claim have only one intelligent gateway on the left hand side the visited side the gateway there there is no intelligent gateway on the right hand side the home side for a start to the claim isn't disclosure if you can connect to any external network you can claims thirty five and forty also asserted claims in this important point in the claims themselves claims functions which mr di matteo calls gateway functions are not gateway functions their telephone functions translating numbers and delivering  providing call assistance all have to be done by quote obtaining knowledge obtaining knowledge that's what makes it intelligence and knowledge from the home network and the way that the i g the visiting i g obtain that knowledge is through an external network connection it has to go out to a network internet v p n p b x direct connection you name it something may be invented in the future some kind of a network and that's what a gateway it's just like m s c talks to f t p and vilar within the network in the disclosure figure what that that the pieces can talk to each other that's not a good way to get way and what a gateway is defining characteristic of a gateway is talking to an the parent is interested in two networks and what the networks of the gateways between it or not some external network it's that room or trying to talk to the distributed mobile network its home network language to get outside the international network so the two networks reciting the claims the two networks at the intelligent gateways working with us roam are trying to communicate to the visited nap it's literally according to some environment to the invention so it's not limited to every single component there and that makes sense because there's tons of options the mobility approaches an option the home network there and of course this connection to the that is a classic example and i agree that definition definitions of break gateways that access physical boxes are between two networks that's a functional unit have a functional unit vox's is what we call and so the definitions include that classic gateway we don't we don't deny that and their environment but i didn't see you point to any definition that it really doesn't have to interconnect to network there's nothing about the ok and the computer company connection being made by the intelligent gateway and this time its connections are romer's trying to make the visit it now for using its home network dialing sequence because what's happened is sleep between the rubber and the washington network to push the gateway into the washington network and what's happened is that dialing sequence gets passed first to the intelligent gateway so that's one network dialing protocol and then back to the mobile switch network there is nothing that mandates a connection to perform that claim function of dialing and that's what the kinds call an intelligent gateway to translate is dialing is very clear realm where copy exact function that you see in figure two but for the inference the narrow claim construction and the over reliance on the dictionary definition