broader stanning of mac address their descendants want to argue that apparently express we redefine the term to be limited to being confined by the hub now that's a heavy burden to say it's an express redefinition and they hang it all in one sentence in the one sense in the specification that they rely upon is the said sense that says each day is identified by a mac immediate access mac address and that's it but that's not a definition at sir found in specifications isn't anything in there using art that i say hard that does that's right there's no money meant that specifically uses a universal media access but the fact that but also there's nothing  claims that either are one way or the other that it be universal or that if you're signed by the hub in any of this sort of clans and so it's true that there's environment but it is also true that there's nothing that's requiring either the  m machine we all know what i'm doing we all know what the a t m is we all know how to use it and what i'm going to do with it it doesn't matter whether or not i say for example that a t m means automated teller machine or if i read say it means automatic teller machine or even if i say a t m machine and i add an extra machine to to my phrase we all know exactly what it is i'm doing similarly people in me in the networking field all know how to use mac coins then then maybe a t m means something different that context but in this context there's nothing here in any of this speculation or in the claims that say the mac addresses are special for example if i thought for the mac addresses were somehow unique and different in the specifications of the one point i pad i would expect thought that i would see it and it's scription of what they are how big they are what who makes them how they're made what special why are they unique in any way there's none of that the reason there's none of that in the specification is because the parents he was simply using the well known established way of identifying devices on networks that have been around for years and is found within the intrinsic record in all of the p simile doesn't matter whether or not for example what how big the mattresses are just because the fact that different mac addresses have different sizes doesn't mean that they're no longer found to be mac addresses so you want these claims to can you walk me through and explain how all these steps would be performed using a hard map well the first thing to know in fourteen there is no term mak mak that's true but when we  my universal there's no reason that it couldn't there's nothing in here that says that's not possible and we shouldn't read in a limitation that my definition says well you must be either generator or not and so it receives it and then the hub identifies and says yes ok i want introduces the notion of a peripheral device identifier for the first time with the hub using it it could and then you're saying it could have been received by the hub from the peripheral in step two or it and fire doesn't necessarily need to be accessed coextensive with it so yes it could be the case that the mac address is being sent back and forth importantly there's nothing in here that says you know limits it to being created or generated ernie thing else in that situation  the hard mac peripherals or it could be the peripheral itself that communicates and step into universal right and if we go to forty three there's nothing in there it doesn't say anywhere in here oh it had to be specifically rooted in any of those steps it just says there also is configured a parolee macro so then where is there in the written description these notion that it can be you know the you know we love to say well that's clearly an indication i think of him different i don't think it it certainly does not help them but i don't think it sort of necessarily helps us but that's also crucial crucial because in this case they're trying to express we redefine the specification as you point out your honor where it's not at all clear and it doesn't say actually where the mac address came from that's certainly true but that there are that written description support for usage of a universal knack for the peripheral parser portions where you know that it's at and i'm saying that it's at best and biggest as are the those are the clearest indications of an environment that may have a a universal mac address but what i'm saying is the term mac address as it will understand meaning in the field and it's that univere and they're using that mac address here throughout and so therefore because that universal understanding is implicit all it could there's nothing stopping mac addresses from being  y true but then when we look at the special education and the rest of the pen i mean why is it we would find that there's a disclaimer here there's certainly nothing that arises to clear disclaimer there's certainly nothing in this patent that says you must only use locally defined mac addresses to the contrary it all it just simply has a few embodiment and there's nothing special about the fact that there's a locally defined mac address that's that's also critical it's not like i said there's nothing in here it says well here's you know here's what new special mac address is or who here's how to make it none of that all it says is let's use mac addresses identifiers and the claims help you out here some because there are claims that are not inserted in which it says where are the mac addresses made or made in the link layer of the hub device and so for example you have claimed fifty which talks about where it's made and even say well that's talking specifically about you know player making it and i understand that but there's ultimately the federal circuit ruled that with the appropriate plant construction for double tap right in that case is different because they're talking about what the invention is they're saying this is special this is a special unique interesting thing and we're going to define it we're going to say it's special and unique important to the invention of hearing contrast there's nothing special or unique about the mac addresses they're just happen to meet him i put it in a professional anything about your invention that started worrying about wireless personal area networks they were one of the reason is that what before this as it is discussed in the background of the invention of wireless personal networks either how do you swap the wires or they can basically link could communicate with more or less one personal device b v m was one of the first first groups that was experimenting with having different lots of different p a's or different personal devices attached different times and come on board or not come on board and so that that that as shown in the intrinsic record helped to lead to the tripoli's it a two fifteen working group and that was that and and eventually became part of the broader wireless claim construction and judgment of not infringement because a person of were narry skilled in the art reading the entire patents in the context of that entire patent would understand that the mac address in the one to nine patents is limited to a device identifier generated by the hub the court asked the question what's special about the one to nine patents and if you look right at the title it's a personal area network with automatic attachment and detachment the way that occurs is that the hub work histories all the communication in the network and a person of skill  reading this pattern as a whole would understand that it is the job of the hub to work straight all those communications and the only way that is disclosed in the patent for that to come about is for the how to specific concrete well established unit and i think the evidence supports that and so you know you're it sounds to me like you're trying to potentially inject a certain step or feature into the client that's not actually on the client what we're doing is we're talking about the definition of mac address in the context of the patent in the context of the i trip and we're in the context of a different piece of prior art you need to read the disputed about whether there is a single defined meaning of the term mac address in the art the references relied on by your come from after the date of the invention they say to a two thousand and two i triple the specification that's no evidence of how mac address was used at the time of the invention which predates that it referred to a two thousand and three patent too but now if that's applied you know your best argument that the spectrum how as you know redefined or constricted the meaning of mac address to a particular type back and it's the same as in the simon case as well as many other cases i c u medical where the term was a spike and throughout the patents it was a pointed spike and this  syringe and although the term body mind of incorporated multiple pieces it's consistent use in the specification as a single body syringe limited being vention to that and the same thing as judge chen mentioned inside med where the dynamic attachment an attachment and actually what was important in this patents was the concept the context here is this was a personal area network for a soldier in a battlefield was the history of this and the patent talks about there being interference in that situation and that these are well coward devices that you know you have a battery power that has to last a while in that context the communication needs to be short and actually the specification supports the idea of this short mac address a mac address that's controlled by the hub the mac address in the i trip and we was forty eight it's long the mac address that's in the body when documents that are in the extrinsic evidence and the mac address talked about in this patent is short because there are only a few devices that the soldier might have it says up to a hundred it's a seven bit long mac address that's important because we look at this at the suspect there are short messages and long messages disclosure in the patent of the mac address coming from that peripheral device to the hub prior art you know the use of a mac address link peripheral to the host device infringement should be affirmed because the claim construction was correct in the context of this patent there is only one type of mac address and that's provided by the hub and it serve this purpose of having this reads hachiman in this dynamic system and the short only one meaning to that term what about the language that i cited to your opponent doesn't that suggest that there's there's more than one meaning here there's not in the context of of the patterns you'll see in the figures like figure eleven that deal with the attachment process it is always the case that the mac address comes from the hub so when this when the specification talks about a p e a and leave the pointer come seven which can have a in which that p eight gets the mac address and that's through the attachment process where it's provided by the hub there are these other things called the a max or attachment max those are again generated by the hub the hub establishes a list attachment which you would argue i think is is provided by the hob and then it goes and the one of the hub assigned to the p f a so that seems to clearly suggests to me that there's there's one mac address nine is talking about the attachment makin the first back to college to come seven around wind sixty two and it talks around sixty and it talks about that there's a hub assigned mac address and the other for use with attaching p e s sub selected mac addresses a max and that occurs in this l t e partition which is in the hub so it's the hub that provides the a max provides that different terms than mac address it's the attachment mac which is of a different type and that doesn't limit the term it doesn't apply to the term mac address as used in claim forty three your mac address if you have a hub on your belt from the g p s in your boot you don't want to be interfering with me so the whole putting it a different way there's nothing in the spec that that excludes the usage of the hub universal mac there's no indication that there is a universal mask so you just lack foundation there's nothing there to exclude it because there is absolutely nothing there to say that there is universally assigned mac but if we just assume for me that we and then the descriptions here of the hudson that address there's nothing in there in this back that exclude the usage of the universal for the right would be only processed talks of the the mac generating the hub generating mac addresses and so the process is one in which it needs to uniquely identify something and the hub is going to select a mac address that allows itself to identify itself on the network message the heartbeat message is the p a s are programmed to receive that message they understand that the hub will be generating these messages and when they see a message that has the mac address of the  universal address the pattern isn't directed to how the p e s distinguish different hops but the pattern is directed to how the hub coordinates the communication among the p a's and in that sense in that in the sense of claim forty is all the saying for the same thing mac addresses it's the using the same words it's not and it's using the same and being used for the same function which is to identify devices on the network so the point being is and there's no reason to define in that case mac addresses in the patentee specifically mean only those things that can be generated by the hub and similarly there was discussion about well you need to be dynamic you need to have things here change on the fly that's not in the definition that the core provided t core provided the definition says that the device identified generated by the hub access there's no dynamic requirement there's no reason i mean that's all that limit in the courts definition and so therefore to add an extra baggage at this point would be improper but it's really just the rationale for why the judge arrived at that quick look at the suspect it's all about the dynamic attachment you know detachment the attachment there that's right there certainly dynamic in the sense that there  does show reattachment an attachment that said there's again nothing in the claim that's required and so therefore there's nothing that should be reading from those an audience into the cla