support your argument that these are mutually exclusive wired connection and decided that even though it disks describe a wired connection it didn't preclude a wireless connection however  i would point out that the the computing devices or hotspots refer to a specifically state wired connection between for example a hotspot and ip based network so if there is a wired connection there it is not wireless  don't live in indicating that there are other wireless networks there are other possibilities in addition to that there are references in common to beginning one thirty five going down the line forty seven where it references why if i access points and it describes why i find cellular and obviously if access point had been intended to be redefined there would be no need to two point eleven networks where our wireless networks do you think it's referring to here other than to the time of the invention some some of the networks were able to eleven networks the other networks that were in popular use were cellular networks and that's how around the two thousand and six two thousand and seven timeframe a lot of computers or laptop computers would connect to the internet using network cards that were often the cellular network in this the cellco providers would sell network cards for example  at the moment i don't see references specifically to cellular but at the same time there are not references specifically to why fight there are references to wireless those are simply wireless they can equally refer to cellular network interface cards as they could a wife by network interface card jim in terms of the disclosure of the invention yes it it relates to wireless and it's not restricted to any particular type of wireless now there are certain  there are a number of inventions in here that there are there's over thirty counts of disclosure so there are some inventions that are described such as the viral spreading that would lynam selves to wife i but other disclosure other inventions are not a lot of this invention goes to the handoff between from e client to another hot spot or sharing of hotspots between clients and so forth those and relate to other types of wireless and specifically if you have a lot of things where you say could be one or the invention at least a wife by connection is what the access point has to have in general third there's more than one access point so as to between the hot spot and in the client's that is often referred to as as wife by hot spot and the ip network that is a completely different access point and the second access point the first access and first access point which is defined in the claims as being wireless right yes it is ok it is turn our concluding that there was a definition i think that there was a clear definition here on earth but i don't think that the argument definitively turns on because that sentence that  private hotspots the locked kind with as access points so i'm not sure that that sentence meets the standard of clear redefinition of the term with i think what is what is an order and undisputed ordinary meaning hence my focus on the spec as a whole what does it tell you this i don't not at all sure that winds starting at like lines thirty where it says currently there is a growing number of y five public it's per hour and or access points quotation a p s so clearly there is a definition going of an access point i don't think that the word or so that's neither disjunctive nor the positive right but i don't think that that's a typical meaning of the word or in the english language that's that's what our opponents suggest and let me give you an example and this is what we went through in the district court during the martin hearing you might use it destructively like you said between two alternatives to say i want a soda or a pop and for those of you not from lee we have to separate examples but what you wouldn't say is i want to beverage or t v where you've got a general phrase and then you put in or conjunctive lay with a more specific example that's just not proper english usage for the word or in this paragraph i think that we think that it is clear that you're using or to redefine two different sets of terms with different words to mean the same thing it's just like the pos technologies case the conclusion that the court came to there with respect to the way that or is it religious which term in the three word phrase do you think that that the phrase access are public they're just blocked there's a different type of hotspot that's actually private so like if you're you know on your mobile phone and you hit the security button and you're trying to look for what hotspots are in this area if you actually see it come up even though it's got a lot there those are public hotspots they may be locked but they're still publicly accessible there are other hot spots and there might actually be one in this court that won't even come up those are private hotspots as i'm walking through the court i would say let the wife i ask but my home is a public hotspot it is it is public in the sense that it could be publicly accessible and if you have not set the security  so that you require a password it absolutely yes like in apartment buildings and happens all the time that people have the same exact spot that you have in your home but haven't such security and they may have neighbors that are you know the chain on of them so i think that there's a in contacts the contacts tells you which way the word all or is being used exactly the way that the court looked in pas technologies you know is it being used destructively to separate two different alternatives or is it being used to redefine in different words really the same concept so i reveal to you that those are two different ways to use the word or but they're both proper they're both exactly acceptable within the english language  and one of the things that our opponents said was i think i would have outside a quote there are other differences i read with you there are different differing clues as to whether or not it's definitional but i think that those are completely appropriate uses of the wor with the what is it a go to play the living standard is being used for a certain wireless communication as far as i know your honor but that's far from definitive but let me see my point was that i e and all are actually used in specification interchangeably if you look in the next paragraph from where we were in column one and now i meant line thirty eight and this is getting to the point that we've been discussing in that other a p s are placed by individuals in their while i think we know from the context if you start with the column to line fifty two where this phrase is taken it's talking about the concept of the hand and it says this concept of handovers is taken from cellular networks and numbers usually in the explains manage networks it says the network operator in many cases chooses to add cells where coverage or capacity needed in managed networks the a p is and then it's referring back to its analogy of where it's taking the concept of handovers from or cellular cells are synchronized and so i think it again is that is the support you have for the idea that this invention doesn't at all envision the use of cellular at all so i think one thing that you already pointed to is the fact that it says very clearly at line two starting  excuse me column two starting at line thirty that what we have is a service that is going to compete with or complement cellular that is a very clear statement that this in mention is not cellular it's something that the this area to ok lines thirty two any and thirty four is kind of the key phrase that this service is competing with or complementing cellular service that's very clearly a statement that the throughout the background and i had five goals here stated point of reinvention i was going to point you in the background but i'm going to switch gears and try and do it in the other parts of the specification because the same point can be made you can go through the a that parents had a goal seems definitional and i think maybe you treated as such is that right i believe that that's correct yes we go in so what do you make of column five lines thirty eight thirty nine that to my eyes rita uses the term s t a to refer to any old cellular phone without any reference to wife i capability access points when you put a p in quotations all of these things are suggesting that you are defining the term and i want to get back if i could for a second to george stalls question about the remainder of the that's the case then and i think this answers your questions do my opponent was not able to cite you anything anywhere else besides the background where cellular is discussed but what i can do is point you to several places just just as i mean this is like a deposition question or something she wasn't able to are you i am thank you thank you for the opportunity i could point you to several of them and i think what's key here is that a number of them come with the language and now aspect of the and do it quickly a little bit on the fly but column eight line fifteen it says another aspect of the invention is to prevent exhaustion of resources pretty quickly ok i'll try and give you these very quickly the resources point goes back to this but goes back to the background where it says that why five protocols have limited resources the wife high standard only allows you to connect to a certain number of of as she is so that's one wife just a few lines later another novel aspect of the invention is to save battery power and reduce network load by reducing the number of location updates security only a wife i problem not something that's true of cellular column nine lines twenty one another novel aspect of the invention takes advantage of the fact that the wireless network until the life you're sent wireless i might have around here but the wireless network is local again that's true only of wife i the very nature of cellular is that we're looking at wide access so would be part of section one twelve in the written scription requirement in this case the district court order was was just in the area of claim construction so the written description aspect is it's separate from that i would also point out that there is the alleged three definitions didn't accord with any i would also point out that in the context of the invention for example generally claim one of the three zero six claims a  computing device that serves a client and then is also connected to the internet if one were to call that computing device a hotspot ninety percent of this invention describes how that hotspot facilitates communication with clients how it provides address packets it doesn't have that there is no limitation on how that hotspot connex to the ip network or the internet there's no requirement that that hotspot can only connect to the internet through another hot spot which would be