please the court the sole question on appeal is whether the forwarding card disclosed that all reference satisfies the processing engine limitation of the challenge claims and whether it is capable of performing the more protocol limitation  but there's expert testimony that someone reading my dell would understand that and if that's true that dell contravenes that testimony and we think it's pretty clear but even if it's true that you  reasonable alternative interpretation of well isn't our question here whether or not there is substantial evidence from which or reach upon terry factual conclusion yes that's a standard your honor but if an expert different kinds of protocol data despite what dr levy and may have opined it's clear that that just isn't bell's teachings well i don't see where bell says that you can't do that well it was a question of whether it's you should and that's the passage ending with the other protocols can also be implemented a sentence that dr lavie and relied upon in modifying figure thirty six b from bell the very first sentence in that passage reads the ing interface chip will be specific to the protocol of the data within the path so if we start adding ships to position five eighty four b the way that dr levy and has proposed then the in grace ingress interface chip won't be specific to the protocol of the data within the path any lesson to be true but you could have multiple chips on the same card the process different protocols first of all there is no evidence as to why one t m interface chips if they're not then it can't do this teaching the bell sads is what's supposed to be done in a system we also have column forty eight lines forty one to forty two bell teaches that a forwarding card in a network device is similar to a line card of a computer system but you put on an expert testimony articulating the arguments that you're making now we did it was rejected by the board your honor processing engine but really that argument is unnecessary to what we're actually saying it doesn't really matter what is identified as the processing engine bell it has to be capable of satisfying the multi product all stations and all of the script of these these ingress interface chips in dell suggest that they have to be one and only one protocol that you can't mix and match the way dr lavie who suggested again going back to what  bell said about forwarding cards being similar to line cards in a computer system he actually describes lying cars as well and what he says beginning at column two line  card sixteen you could be a card that implements internet protocol ip over sonic is indicated by a different card type with zero problem i'm having is you're asking us the act five years here and you're asking us to treat your argument is expert evidence that contradicts what the board said that smart job of a prof we're not asking judge we're not asking you to the effect find a rescue to review the findings by the board in light of the evidence that was before contain multiple references to flexibility and capability of handling various protocol data streams i mean why aren't those relevant to that to the ultimate why doesn't that constitute evidence upon which the  in concluding that that there that your opponent's expert's testimony was was worthy of consideration because the flexibility evidence that the board cited to them in fact again says read on your honor similarly each universal court card may support a different protocol e g sonic ether net a backup or spare forwarding card or universal support car must support the same protocol as the primary car were cars again there isn't a special category of primary and backup forwarding cards and bell the whole point of the flexibility is you have a multiplicity of these forwarding cards that you can switch traffic to as needed so you're not going to have a primary forwarding car that has a multiplicity of protocols processed by it and then have a backup forwarding card that's only capable of a single protocol in one configuration but it doesn't foreclose other configurations of which you have chips on a single car that can process different but your honor that wasn't dr lavie ns opinion dr levy and didn't say ignore what bell says about this here is what someone would have done beyond that what he said was this is what bell teaches that thirty six b is merely an iteration bell's express teaching i don't think he relied on this lie about no no he didn't your honor but that's the point he lifted a single passage talking about the ability to support multiple protocols and concluded that within the context of a bell that meant inserting another card additional to whatever stairs opposed to swapping one out for the other and it's true bell does say that the ingress the ingress chip could support multiple car protocols but what you do in that circumstance is you convert it from something that process a t m to something that processes for example ether net you would convert it to something that has a multiplicity of chips each specific to a protocol bell doesn't teach that and again if we're looking at what dr levy actually set the evidence at the board relied upon he didn't say someone reading bell would have extrapolated well to do it this way he said this is what dell teaches and the only way it teaches that is if you take a relatively ambiguous reference then in the context of the entirety of that reference what bella saying is you can have these interests interface cards and you can have a multiplicity of chips in their but they all port cards id one for each protocol support so again what bell is saying is if you're going to have a multiplicity of these protocols being handled you have to have a multiplicity of forwarding cards meaning a forwarding card is not going to be capable of of receiving and processing multiple protocols and dina is a pretty detailed evidence and multiple different passages from now i think in order to put this in context and some of the additional statements from bell are important so if you look at the networks which is a hole in the aisle it receives data through what are called universal part and the reference indicates that each external network connection may provide multiple streams or paths and each stream or pac man include data being transmitted according to a different protocol and uses examples a t m and kill as ip and frame relay and that's at a forty five sixty four column fifty three lines fifty three sixty four so multiple different protocols come in through the universal work cards on different paths then the next step is that those has of data are transferred to the forwarding cards and what bell says about that is that any port on any universal port card can be transported to any port on any forwarding cart the logical inference from that is that i has now urged the court to interpret that as saying that other protocols can be implemented on other forwarding cards but that's not what the passage that the passage is talking about a single fording card and it says  example and interface chip on that part could be a t m but other protocols can also be implemented and that language can also be implemented is important because in talking about this specific a way that is advantageous to the network administrator and you can swap out components and that's the whole purpose those of course some of those embodiment are directed towards situations where you might want to have a protocol the civic working cart but other implement ons including the implementations where bell talks about sending any path to any forwarding card and indeed the implementation that's discussed in column fifty lines thirty six through through fifty talk about a situation where  fourteen card could process multiple protocol is that the only place that that you rely upon to say that one card can process multiple protocols so no so so column fifty is one example in addition there is some language that the fourteen cards are similar to line cards this is at column forty eight lines forty three forty four where it says that the the line cards can be unable to receive in process a single part protocol or alternatively each port can be enabled to run a different protocol so that's another disclosure where the fourteen cards are being compared to the line cards that are disposed earlier in the reference and the like hearts process multiple multiple protocol i think also the important thing here is how these passages end bell as a whole would be read by one of skill in the art and the only evidence and they never submitted any evidence from an expert or one of skill in the art as to how these disclosures would be read and so all of the argument is just attorney argument and what's important in this case is not what i think it sixteen be said that each line card supports a different protocol but multi port reference of mr carson referred to is that there could be a serious series of ports connected individual line cards each supporting a different protocol if a line card is analogous to a forwarding card and that means that each forwarding card supports a different protocol in order for a forwarding card to be a processing engine is claimed in the pattern in question each forwarding card would have to itself process a multiplicity of protocols so the very passages miss carson a citing what it basically says is you can have one forwarding card for one protocol another forwarding card for another protocol and a third forwarding card for a third protocol w through these this multiplicity of in this case wind cards you have to add another port and another forwarding card or another line card in this case that itself is able to process a different protocol but that's not the claimed invention is all about it says a single processing engine i e one line card or one forwarding cart is capable it on its own a processing a multiplicity of protocols so the very passage you refer the court to in fact says precisely what we say bell is teaching which is if you want multiple protocols processed you have to have a multiplicity of line cards or forwarding cards by analogy and bell teachers know where having a single line card or forwarding card this capable of processing multiple protocols in other words the