starting with the claim term camera unit in the seventy eight patent the district courts claim construction order committed what this court has called one of the cardinal sins of patent law reading limitations from the written description into the claims instead of this court has enunciated many times the name of the game is the claim to determine the scope of the invention of the claim must be consulted st claim is the most important evidence of your well that's certainly one of the questions but in their portion of the specification you reference a column for line twenty three dollars it begins in principle which as i understand the idiom means without regard to the specific details and then it says by example the camera card consists of and then it enumerates elements in that example but this court has long held that even if that were the only embodiment scores in a specification that doesn't limit the claims in the claims here for example claim one specifically defines camera unit and what it is comprising to have five elements so under the legal case and the carriage technologies case even if figure five were the only includes those right in that example it includes those things can we unit has different needs and different places yes we believe that camera unit is not camera is a term that everyone in the art would understand camera unit is not an term of art and so there is an example of what a camera unit is in that portion of the spec that you reference and i don't think your five claims specifically defined camera unit to have certain elements and those elements are different than the sample in the specification this isn't a case like the cases that samsung sites where the patent he has repeatedly and consistently said this is the invention this isn't an invention about a camera unit and having special items that's not would be invention is about and it's it's not like those cases this is like the other cases where there is that example in the spec and there's also the example in the abstract it doesn't have those elements and then the claims specifically define what a camera unit is specific and you can tell that they do match up and you're correct it is a little bit more difficult than normal because those words are not used but one of ordinary skill in the art could match up i think everybody here today including the district interpreted in this patent interpret ing means comparing and what you're comparing is the spoken identifier to the store and some identifiers if you look at figure three three o two relates to the means for receiving the sub identifier in the claim and then at three o three the comparing begins this is the calculating of the probability and that means for interpret ing structure is from three and six because in this period and interpret ing means comparing and then that means for selecting starts at three o seven so no doubt there interger really related and they were discussed in the same structures and i think that could be seen more clearly if we just back up a little bit figure one discloses this voice control unit at item two and the voice control unit has many s hurts and part of i think what's creating confusion is that our words ironworks constructions specifically identified which sub parts are involved in the means for interpreter if you look at item two all of the items in the voice control unit are hardware except for the voice recognition means sometimes it's called the speech recognition means sometimes it's called the voice recognition means in our construction it's called the voice recognition circuitry in programming all those are the same thing but a strangely worded name for the overall mode that means for interpret ing starts at fifty nine the voice control unit calculates the probability and then let me just take a look and see where the means for selecting start so the interpret is the comparing and then the selecting is after that that means st selecting starts at five there's one word on fifteen after the probability has been created so after that comparison then the phone makes the selection selecting that's the means for select so you compare which lines i'm saying that the means for interpret ing starts at fifty nine and goes u and so if it tries to compare is she saying is she saying more is she saying laurie and then based on which one it thinks i'm saying based on that comparison and it selects so they're there integrated into girlie related and they're this is part of the reexamine prosecution history talks about the voice recognition means comparing the received identifier in the store identifier everybody agrees that it's the voice recognition means that performs the interpreting it's all throughout simpson's brief use it to interchangeably is talked about in the real exam that way and that the only view of the person of ordinary skill in our value also says it and treats it that way the question really in finding the algorithm is what does the voice recognition means do and i think it all comes down to what's in five hundred and thirty two talks about the comparison made by the voice recognition mean counselors you see it's not so easy to save ten minutes you analysis is proper to look to the specification as the district court properly did i looked at the entirety of the specification and concluded that the camera unit does in fact as a specification tells us conform to the components and figure for conform to the structure in i mean figure five pardon me it's figure five shows a representation of the camera you know the income to have you pointed out the stage for you five shows a block that include the same components the camera units integrated into the device in figure one and the camera units are arranged in a card in figure two and in all instances the camera unit includes the components shown in figure five and that how do we know that figure one says the device is implemented by means of an integrated camera unit figure two says it's implemented by means of a camera unit arranged in a card and then point to figure five as the block diagram of the camera unit there is one camera unit includes the same components and the reason we know that is in column question but let me give the court some comfort on that and we i think your honor even pointed to this language regarding the battery in a column for lines forty three through forty seven it says the battery is mainly used to ensure that images are maintained in volatile memory in the card ok so it's used to ensure that in the card the batteries part of the card and then it says it can also be used for the same purpose in the camera unit integrated into the notebook  mean like the whips along the way i read it is nothing to suggest that the battery there is optional it could perform other purposes for example it powers the camera itself or it powers the microprocessor  the then i'm the next column column five lines three through six it says by virtue of battery twenty one the operation of microprocessor and the memory unit so forth is simply add additional functions and and configurations it don't address what the camera unit structure is they add things like a memory for retrieving image information and so forth like that that adds additional specificity but let me get back to this battery issue because i can see this is an issue where we go to column four lines twenty three through twenty five it says in principle the structure of both camera card fifteen and camera unit fourteen conforms to the block diagram in figure five that that has no ambiguity in it so take care and i'm sorry column four lines twenty three through twenty five where it says the structure of both the camera card is we're talking about the card unit i mean the card in body and camera unit fourteen which is the integrated version conforms to the block diagram shown in figure five and then it says in the clear statement that is stated there is that the structure of both conform to figure five and figure five includes the battery component within the box not not the dotted line but it's includes the camera range meant plus the battery an interface may i'd like to address that in the means for interpretation just quickly so this is a very straightforward issue in our view that there is a complete absence of any algorithm here and the specification does not disclose any aspect of any steps for interpret ing voice commands and you're honest pointed to an ast council about the lines that they're relying on in column five and that is you're correct your honor that that is dealing with means for selecting and while the same types of means can deal with different functions and in electronics we're dealing with a function here of interpret ing a voice command not choosing the telephone number but interpret in the voice command and the lead in to that section in column five which appears at the bottom of column for tells us that the voice commands have not been recognized or interpreted it says the voice control unit has recognized the given command and as the activation command of the choose name process and then it goes forced into selecting the telephone number so that tells us right there that the command voice command has already been interpreted and recognized but there's no steps in the specification interpret whether this is a haste or a number call a number or do something else with the phone there's no steps in here regarding interpret ing a voice command and so aristocrat in other cases tell us that in that instance you can't back fill it with the expert declaration or the like there's no basis for that  where properly held that indefinite now quickly on the means for storing of course the court doesn't need to get to the means for story or means for selecting it agrees that the the interpreter means is indefinite and invalid but i will say on the means for storing it's also a simple issue we're dealing with a very specific function and that function is the storing of sub identifiers that's not coextensive with a general purpose machine general purpose computer microprocessor we're talking about a function of swore storing sub identifiers which can be spoken or keyed in requires special programming if the cat's exception doesn't apply eon holdings tells us that the caps cat's exception is narrow that is correctly decided by the district court and the column for lines nine thousand nine hundred and fifty four which disclosed those steps for storing  line up perfectly with the function recited in the claim which is storing sub sub identifiers and so all i will say then with respect to the means for selecting is the district court conducted a proper analysis one t dollars identified the risk claim the function recited in the claim and then look to the specification as to the structure that corresponds to performing at that function and there's no need to append the word equivalence to the that's the command you have to put do you have to put the phone or the device into some kind of mode to store a number make a call this is part of the algorithm that you pointed to is taking the steps to figure out number that step has already happened the specifications clear on that it's again at bottom of column for line sixty six and sixty seven before we get into the sub identifier issue and pronouncing identifiers it clearly states the voice control unit has already recognized the command it's already interpreted commands but there are no steps set forth no steps up all disks describing for example i want to command the phone is very similar to a risk to crash you can't have the expert come in and interpret this and now say sub identifiers as a command and twist it your honor respectfully so without my time is my time is up unless there are further questions i from what my colleague from samsung said samsung bears the burden of showing that this claim because of this term is indefinite it's their burden and you have to prove it by clear and convincing evidence it's it's clear from everything in the record including the re exam history the specification and the only view of any one of skill in the art that interpretating means this comparison in this patent and it's done by this voice recognition means and it column five the patent explains what the voice recognition means does step by step in an algorithm he just spent a lot of time talking about voice commands and how come five starting about in terms of voice commands and not some by down of fires and i don't i don't understand what that could mean because it column five hundred and ninety six it says the user can pronounce the sub identifiers in any order and then skipping ahead down to fifty nine it says the voice control unit fabulous the probability that what you're saying matches what's in the database and it does use the word voice control unit but the pedant makes clear that this pacific part of the voice control unit that's doing that probability is the voice recognition means or in our construction the voice recognition circuitry and programs and then if you look at we haven't talked much about column six but if you look at columns six lines nine here comes the key part and the sub identifer composition which is given the highest probability is the final result of the recognition the district court took the further step of adding voice recognition and they're signaling that it understood that the result of the comparison that what the voice recognition unit does is the comparison for the district court got confused i think is in the fact that the voice recognition means is just a sub part of the voice control unit he said well there are algorithms here that relate to the voice control unit but it's not clear to me the district court that they really do the voice recognition means that if you look at those portions of the script five hundred and thirty to sixty nine through eleven and then it also point the court to thousand through twenty it says it can be assumed that the identifier is the correct one so you can see again the result of what the voice recognition means does is it performs the comparison which can