which the present invention is involved or in other words whether chilcote would have logically commended itself to mr wilkinson the inventors attention when he was considering his problem mr apparently the saul argument is that code isn't analogous prior correct and that is actually the second prong of the analogous test the first prong of which is whether the whether the reference the prior art reference is in the same field of the invention but the the board o has admitted on page eleven of their brief that the chilcote reference is not in the same field so then the second prong of that and whether the reference is analogous is if we conclude that today why that is not the proper conclusion the first is that that the board improperly defined the inventor's problem when when it characterize the inventor's problem in its decision and for that  address claims fifteen and sixteen you would cooperate your arguments as to claims one fourteen twenty two twenty five so do you agree that fifteen and sixteen rise or fall with those other points yes so the first point is that the board improperly defined the problem the second point is if the problem is when the problem becomes properly defined the problem of the the inventor face in this case is very different than the problem of that chilcot reference face and the third point is that the environments with which the present the invention operates are very different than the environments with which the chilcote reference invention  operates and so the three points i want to expand upon the first point is that mr wilkinson was faced with the problem of providing a mattress or question that can support the weight of a body and prevent tissue damage to create the spring force to reform what mr wilkinson decided was to try to create a spring bias in the actual outer construct of the cell itself and so in so doing what he what he did was he created a few little structure in the the outer structure of the cell itself that would create the spring by us now as a scribe in the application mr wilkinson found the helix shape was particularly beneficial in with within the realm of supporting the human body quote in controlling the breathing moving thing that was actually being supported by the actual flu itself so the board however when determining that the when improperly and are you determining that the  reference was a garment hook for hooking garments but the invention was related to a cooking mechanism for a hose clamp to keep the hose clamp in a  reference is analogous to artist question in fact yes substantial of the substantial evidence standard correct ok most of your brief and the cases those cases do support those cases do turn on the question of fact in the board or the court in those cases decided that there was no substantial evidence that was the same and let me say this ok i'll make it clear i don't know can you identify turn to the second point the second point being that the that the problems the actual problems which are trying to support the load of a user or of a patient is what our actual problem was whereas in  pressing the bottle you are what you need or what chilcote is describing is some kind of arrangement that when subjected to a force will  and when the forces lift it returned to its position why does it matter whether it's a finger created force or gravitation for so my third point was about the and for different purposes so here we have the same the same the reason why it matters because the chilcote reference there's no pressure that the internal cell is having to maintain when you're pressing it it's just expelling fluid and relieving pressure in our case we're operating a high pressure is where he believes that the pressure is of actually having to support a lot of bodies of the pressures are totally different and the environment is totally different for another reason being in in its description so basically contemplating a disposable device in ours our environment is not something that you can just throw away you're sleeping on it it's you can't throw away that every time you get up from and i think and even when you're sleeping on it it's having to decompress multiple times and as we described the helix was particularly useful in maintaining that the job of the positional geometry during those compressions and expansions so they're totally different environments and so the question trying to solve the same problem that it was not an under the operating under the same environmental conditions so that that's really the inquiry and whether something and out the something analogous is not whether the the exact structure of the he looks is shown that's not and the court found that a simple mechanical invention can still be palatable and that the hoosier hook was not a an analogous reference because it was for a different feel in a different probably trying to solve a different problem and that you're here  after an external load is removed and the fact that is there any is there any evidence in the record that shows that a person of skill would have thought it obvious to him employ methods for oral administration medications to reform pushing it you're administrating a liquid to a patient but the fluid cell in the mattress is also a liquid a fluent cell that dispenses the liquid into the reserve of the mattress when there's a support on it so narrowed to supporting a body in a mattress or cushion that that's that's essentially collapsing the reasonably permanent test into the field of invention and i think this also this idea about that the cell has to support the