yeah i don't think it's fair to characterize it as passing information i'd say that snow there are those cases that are similar to that where you extract information and story conventional way and certainly if what health trio was doing here was scanning health records storing them in a computer and making that available that would be completely different but we have two aspects here that make this different than that and there are improvements in computer technology we're starting from the point where there are electronic medical records this is not computerizing unknown business practice either because we're past that we're starting with incompatible databases and so the first aspect the normalising of this data is not just passing the data around is the rules and you know but generalized directly to the computer to implement the normalization formula it's not it's not a general instruction to do that it's a piece of software that does that th implements the normalising and what normalizing the ends as the the district court said it's a series of discrete steps that are required and when they are executed you end up with a new data form what that does is it recognizes what the data is make sure it's in the right field creates a new predefined format and then addition to that creates additional relationships between the data so that's why it's different than say translating the transliteration programs which simply would take the same column in one database program make that column in another database program with it uses different software or a different computer how does the rose claims data there might be a hundred thirty different ways to describe hypertension and it recognizes what those are by the codes and then assigns a universal health care concept code to that so for example if you look at i think it's on page nine of our brief and also the in the appendix of what that pay our claims data looks like it doesn't look like anything a human can read it's not it's not like a paper record and so it has to recognise those codes which have to be programmed into the rules engine that says if you see this in the pale or claims data this is what it means and this is where it goes and that's basically the rules engine does it's a piece of software that can do that and that's not that's not translating or transl programs but i think i could write a program that says if there is then this well of if those are the basic tools of programming that's true and if you break it down to that level then i suppose no software's battle but there's more to it than that it's what is actually the function that is perform and what does this normalizing enable someone to do well by creating these relationships between the data for example somebody can query that data in a way that wasn't possible before and data structure the format of the data the structure of the data through my remarks all id is transformed into software which move information and it's of all your honor i don't think that's correct that is just moving information around it's creating the relationships between that information that allows it to be used in a different way isn't almost mental steps there in middle steps could not be very high powered mom it's not possible that we're we're doing w at least for the personal health care records data is the health care providers records that specifically in the clients you don't go to the hospital you don't go to the doctor you don't use that you use the insurance compan if that's necessarily think your claim to have problem is when i look at this and look at the claims i don't see anything that actually describes you know what you think the invention is in detail  to show that it's actually not just doing regular translation that you would normally give out any kind of computer i mean this happens all the time in all kinds of just very databases where people write software to say we're bringing data from one thing that has  cases you don't have a claim construction we do here and so that that term those words mean something and the court gave it a very specific definition a specific process set forth as a series of discrete steps to more original formats is from various sources is analyze and converted to a new form analyze being important there because simply the conversion is not enough i'll also second part of my answer had pointed to what it's more it's more than just compatibility first of all by normalizing that you are you have a pre defined format and you're making sure the things are in the right spot compatibility as i said it could be just taking the data from one column and one software  programming program and putting it in another column but you would know what that data is so you have to know what it is and make sure it's in the right place and second as a result of that new relationships are created between the data so for example the the idea of what i  is this procedure covered you might have to look at five different databases to say you know is this person enroll is this a provider of even go to is this procedure covered what's the client's history on this by normalizing and creating these relationships you have something new so you've got to do this i hear i mean but to me i don't understand and let me just not hide the ball here what i want to i'm trying to figure out in there is whether this is close enough to  the type of new database that is created is not the same as in and fish i will grant you there is and there is a different aspect and the two aspects are as you have created a new structure that didn't exist original data it may not be self referential for example it was as it was and but is there and i don't mean to interrupt but this is what i am concerned about is there anything in the claims for the space he shared that describes is or any other thing that would show that this is a new type of database as opposed to just using some other kind of you know preexists existing conventional database structures out there and writing new software for that would be close to one fish the database itself is not like an infection it doesn't have that that that signature difference but we do have our new data structures that did not exist before there were a generic computer count components that were used and there was a step limitation in there of enhancing the record when you did correlation between these two pieces of accounting data and enhanced the record that's very much like directed to is merely the manipulation of information reciting actions such as receiving data extracting data classifying the data changing the format of the data altering the structure of the data creating records supplementing records in categorizing the record entries pretty clever isn't it didn't strike me as being especially clever not of inventive not even close in my view as noted in the electric power treats claims like the is drawn to the collection and analysis of information as being within the realm of abstract ideas essentially mental processes that the information they are merely invoked as tools to carry out the idea there's nothing in the claims that can be said to improve the performance of a computer or the function of a computer in any way software could improve the function of computer and on the any fish case i think is an example of that in a way to build logical structure of software aside the information from the clients and so i don't think there is this as difficult a normalisation patterns and particularly the rules engine part of this seems to me like they are trying to suggest that they've wishes that it could come up with a system or could describe a system that could determine the meaning of data without it without looking at the tires my problem with this this point and i don't really know what to do with it at some point we get to an issue where if you describe what it's going to do sufficiently if you describe a rules engine and here's what the rules are going to accomplish they're going to take all this disparate data then doesn't it become something that a programmer with ordinary skill could in sufficient detail that would enable a skilled computer programmer to just do it and not should be enough should it agree with you and he said for example make it go here and when it goes here make this happen and so on you could describe a software program that our programmer could ride and the software programmers do that all the time they draw maps before they wri then the math would be sufficient and if it's describing a technological solution that would be pat knowledgeable in my view that's not here these patents do not describe any technological solution it's an aspirational suggestion that the computer the rules engine determines the meaning of data magically from its context there's no disclosure i have a background in electrical engineering  computer science i have no idea what it's talking about how it would determine the meaning just from numbers ninety eight point six is that my temperature or set my body weight how would how would the computer figure that determining meaning it does not include the notion of creating relationships these are all pulled out of the specification and there's no recitation of claims of those concepts so i would suggest that because of that they should know those kinds of should not play a role in the court's analysis of this issue as was done essentially in the fair warning case where your i guess i would like to briefly address the representative claim issue although council did not raise it in his argument the health trio fault the district courts you should represent the claims in its analysis yes all hell trio does is make the obvious point that the different claims of different limitations there is no argument you know any developed argument that i saw any of the briefing that different limitations made any difference to the analysis of the one issue in that news view of the differences don't matter to the limitations other limitations of all the other claims are just as functional just as result focused just is descriptive of mental steps and mental processes are a human activity and an equally devoid of any technological solution as the limitations are in the represented claims substantive argument was made as to the separate patentability of the other claims in the same is true here in this result lists of myths that represent a clean treatment that is appropriate for the same thank you your honor the question of whether the rules engine has adequately describe its goes over into enablement and that's not before that there is a description of what the rules and john is and what it does refer to the drawings the actual instructions are they could be they could vary and so that's really a question of could a programmer are given this guidance as to what the don't see there's any way around that by saying i'm going to exclude the inventor concert from the abstract idea and then not consider it in the second step of mail it has to be one or the other and there is something in the claims and to say i'm not going to ignore it