particular report and there's really one dispositive and i submit uncontested fact that shows that this is true hiring teachers generating reports that must include at least one necessary piece of information and that is the head or topic of the tire report such as a medical problem and that's exactly the same type of the choir's late information that the patent describes for example a medical problem and not requirement entire in the stablished in advance based on an expert  teaches that disputed limitation and that theory we further said that was fairly and clearly spelled out in the petition petition states that tyra uses quote experts to find models to target specific information what are you reading from brown this is george soros so it's your view that here at one thousand and forty six where it talks about targeting specific information that that means it's required when i mean i i think it's you know  the information that is found and you could create different reports based on the information found by the patent and the claim is understood by the board is that you're going out you're seeking specific information required by a form is that how just stepping back is that how you think the board understood her to work and that was the difference that the board saw i think that fairly encompasses the difference between information so for example entire if a doctor steps up and says i want to report on anomaly that is the required information because the report that's generated if there is one must have  and explains why the required information prior to the work required again until the end comes to that but it talks about targeting the expert to find models with specific information and then on  petition you know like the board said we need to explain that you needed to say like when you're talking about targeting specific information or important medical patient you have to say that it's true that need to treat quite so i particular report and then it says why because unstructured records are structured dictation reports could not be submitted to insurance companies or regulatory there again is saying that there is certain information that must appear in the structure report entire of this latent information otherwise it wouldn't be useful and then if you trace through the steps and i sat back and ask you another question about this i think you're talking about where it is a potent pose it would have been motivated i think the board said this wasn't sufficient because it was part of your motivation statement and i understand your response to be was not just a motivation statement it's also talking about combining tearing the canon to include late information required context of these three pages discussion what we're getting at is what's the required information for inclusion in these reports and then that same required information that later information you see it again throughout the steps of the  declaration made the same point that both of them acknowledge that there are problems with non structured information and therefore you would want to structure it in certain ways for other purposes and can you get back to the things that you started the argument about about something about  five grams but not the word mass as a topic respectfully disagree or honor it st you get the topic and then you know what else you need to look for and so that's why we say bit because this is probably the most important part of your argument so you could please do that point out where you're relying on seventeen i was there and also you referred to seventy one but if you could point out your point better thank you absolutely your honor of course i will start with a seventeen i'm looking at the right hand column three lines down under the frame constructor heading where tyra says each frame petition that's a sentence that the board itself acknowledged and i don't think it's disputed that to have a report in terre you must at a minimum have a certain piece of required information which can be one of three that has to be contained within the report so that tells us that the expert define model is something done in it and this is why we submit that even under a narrow view of what is required to hire a definitively teaches it for exactly that says please give me a report on any recent chaos our citing case then there is no particular and the clerk being diligent generates  a report with thirty seven such cases no one of which actually was required by the judges request i kind of think that's sort of what the board was saying  here i agree on i think that is what the board said and i think that's wrong if you look at the specification let alone the claims that don't provide any sort of restrictions on what is required but you look at the specification it says any reports can be generated information you have to have at least one case that's a requirement or a doctor saying please give me a report on all of the anomalies identified in my free text narration from the last week therefore those anomalies are required and pointed that out in our brief thirty three and thirty four and nuances response to what i think is revealing at page fifty four the only response newhouse has to that hypothetical is that no that doesn't work because you need quote specific information predefined as being required for accurate and complete reporting on a type of encounter and that requirement is not part of the work required it's not found in the claims and we submit it's refuted by the specification information quiet for generating a particular report because both references knowledge that reports could not be submitted to insurance companies or regulatory agency structure dictation so  why isn't that enough when the difference is whether someone's decided with the information you know whether information's required or just important why why isn't the sentence here enough for that claim  typically do you think the board aired when it said that this sentence doesn't provide an explanation for why you care and you have the canon teaches the required element no i don't i don't think that the board erred in this regard i think that the board properly read this paragraph a setting for a motivation for combining tyra and light if you can in which they no longer are relying on an appeal to the motivation for dividing those two task is to create expert defined data models of the targeted information contained within the report and he's saying that what this means is that basically your take as i understand that is they you're picking your motos uses to identify what entire is the identified leaking information and they point to a quote from title and the quote is the existence property location and diagnostic interpretations and those properties  to suggest that they would have or that they did they pointed to the information and they point to the report and they left the implication that that information was required for that report and we would respect  area like that where you had the required for language was actually added during prosecution so that the claim went from saying simply identifying league of nations to identify may be required for a report that they're leaving that partic mutation to implication is insufficient as the board of a property find it would be insufficient to carry the burden of proof and it was certainly not of use of discussion for them to conclude that it failed to comply with their rules that required detail explanation we've been going over different aspects of the same ground but if if one and i guess returning to where mr bell started about this idea of a head unstructured dictation or reports are really not satisfactory doesn't that make clear that there has to be a structure which and it's a little hard to see how there's a structure without a head or i think you could certainly have structure without either you have you now see that i find most useful i taking the form that you submit when you're going to pay for some clothes you purchased online that form how many fields and so every field could have could be compiled optional typically the field will start and it would be structured back and so you just put in your middle name and your apartment number and you had to make it would be structured in the sense that you have a billing report to identify those two but no one would say that that information was required to generate that report in the st instance and i at least related in my mind i'm not quite sure how related putting aside what's what's in these pages on the petition and just looking at tire where it says topic and referring to the frame is that word piece of what the petition identified as a latent information the the dictated radiology reports entire does that information include the word mass when the information is about mass the nd and i think that gets to the question of whether or not that is leaking information and it goes then the reason and most of my expert testimony on it i can point your line is that this just simply wasn't an argument that they presented before the board showing  match report entire which is a subsequently generated report of tire references in its disclosure they pointed that at the the report that what for which the late information would have been required so before the like to start with the last topic of discussion and if i could point the court to a fifty six strong to your question about whether in the petition the topic was ever identified as part of the information at the consists head or topic and set of property so that head or topic in this case example a mass is required information i don't think there's any doubt about that and that required top it could be a match and also at other pages throughout so we think that there's really no doubt that there is at least one piece of required information for tyra's report to put it somewhat differently if you end up with a report  must have at least something filled in in that area whether it's an abnormal medical findings or a procedure or something of the life that is required now and just it's just to be just to be doubt that further to that of the topic or header that is part of the required information i would i would be hard pressed to say that there's no doubt about it maybe you're right but apologies for the overstatement i don't take it as contested at least entire you get a report it must as a minimum have that piece of information and therefore under any reasonable definition of the word required just as when a judge requires a report on something even if it's not specific information you know in advance you know there is a certain type of information required and under the plain meaning of required we don't think anything more required so we ask the court to reverse the board's erroneous determination under any reasonable interpretation that pirate does not teach this contest implementation and remand the board to address whether the prior art teaches the other limitation if there are no further question