intel's key arguments which affects all the claims we are using our petitions that takahashi discloses determining whether to power down a portion of the cash and could be combined with who's comparison of estimated power gain in power loss the board acknowledged that in its institution decisions but then in the final written decisions the board refused to consider the argument that was error and v l s i has no meaningful response the board's decisions on institution make clear that one aspect of our argument was that a skilled fifty four and that's the point you can take the determining from takahashi and to the extent needed modify it based on the comparison of loss and gain in food for the board to refuse to address an argument on the merits that we made and that the board acknowledge we made i based on that the k includes in that sense it does satisfy in determining step what i thought the board was saying about who is that it doesn't power down based on the relationship between the l to access the leak ratio you contend that affects the decay interval determination and so there is a relationship so it really isn't a question is it as to equals one hundred dollars then small decay intervals less than a one thousand cycles are detrimental to both performance and power this is because short decay intervals may induce extra cash misses by turning off cash lines prematurely this effect is particularly what you understand to be saying i must confess your honor i have a hard time understanding what the board makes of the of the fact that it's a simulation i mean just because who is benchmarking results for four different l to access to lead ratio values that that doesn't mean that the values aren't being used to determine whether to power down a cash i mean if one looks at figure ninety one can clearly see what who is doing which is they've taken the four different curves the four different represent the four different ratios which are at the top of the chart and they them to show that the energy saves compared to not having a power down policy at all based on the various decay intervals and it shows that there clearly is a difference as to the optimal decay intervals which is the minimum of the curve depending on which ratio you benchmarks and then based on what your actual chip specs are you can figure out which decay interval is best for your particular system the idea is that this can be used as a model for an actual system based on actual estimates of else you access to leak and in fact who has a review  still recommending indicate interval for almost all the systems of around eight thousand but when the ratio is really high say one hundred then any decay interval shorter than a one thousand will mean that the dissipated energy that that occurs due to increase misses will quickly use up more power than you would if you didn't power down at all our expert dr i've not done explain this in detail so i think this discussion reflects exactly what who says it's about and in the language that the board quoted on a twenty the basic principle of the evaluations is to measure the static power saved by turning off portions of the cache which is the denominator of the else you access to leak ratio and then comparing it to the extra dynamic power dissipated by turning off qualify as representative of the estimated power loss but it said that by comparing it to a pre determined value takashi was not comparing it to a proxy for estimated power gain and we think that's incorrect because takashi does exactly what the and then it compares that to a pre determined threshold that it calls t h and as the board noted on page eighteen of the appendix the patent doesn't disclose the value of the threshold it doesn't even disclose how it's determined but it's clear that they're not measures of power on dynamic power so you don't do it but if it's below the threshold and saving the leakage power is worth it so you do do it so we would say that because talk of high speed disposes and indistinguishable implementation from the old one for patent talk and how she also discloses the claimed estimated power gain and the board clearly erdem was unsupported by substantial evidence in concluding otherwise so for that reason and also for the reasons regarding the talk of how she who combination that i was discussing earlier we respectfully submit but what i'm suggesting to you is that's clearly wrong right they did raise it in the petition so it is our position that what was raised was that the pot the entire element of the term determined element said this doesn't show that there is a relationship because of the simulation i i really don't understand what that means there is a separate point about shows the relationship what difference does commission was made maybe that's an argument that mission needs to address but i don't see that that's what commission decided that there were difficulty in making estimates and therefore it didn't teach me that's which is compared to the current measured value to determine the change of the cash missed rate and that change of the cash miss rate is the foundation of the principle of operation takashi takashi does it powers down the portion of a cash check if the cash in its rate power gain is absent it is merely the last measured value in this rate as compared with the current value to see if there's been a  change ok anything else you need to tell us like easy eleven more point i'd like to make about about who there's a number of additional portions of who have been cited describing how  says that when the l to access to league ratio is high the decay interval should also be higher because if you turn it off too soon then there will be additional cash missed rates that use up a lot more power and will quickly  get rid of or even exceed the amount of energy that you would that you would save by not even having a policy in place saying that who doesn't teach a relationship between decay interval and be able to access the league ratio is just contrary to the plain disclosure in fact that purposes close quote that's why instead of picking just one system to evaluate they focus on the ratios that they can use as benchmarks but who does not suggest that a particular ratio couldn't be determined for a particular system based on actual don't measure power either they use proxies in the case of the old one for patent they use the amount of dirty bits compared to a threshold that the board itself on page eighteen says is not explain what it is or how it's determine