in other words the strike is not the vehicle or the outside portion of the or is the vehicle but the question here is where does the outside begin exteriorly of the interior of the vehicle right so if i think that that language should be read into your claim because of something in the specification and how you define your distinguished cheerier from interior is that right the the outside of the vehicle begins and the cabin seal now the parties stipulate that this is your disease expert testimony vehicle i believe dr hoster was saying that anything outside the cabin seal is where the outside vehicle begins right so we're talking about things that might be positioned within the walls car is something that we in the art identify as being outside of the vehicle question how to understand the import of the intrinsic evidence but my understanding is you are putting duct as an expert in the vehicle are and how people in that field at the time of the convention would understand that for a exteriorly of the vehicle and in his opinion as a matter of fact they would understand something that exists tucked away in the walls of the car as be outside the vehicle and i'm asking you is there something that she pointed to as a basis for that factual  vehicle like outside the walls of the vehicle is where the left portion twenty four dollars is located but to me that that's a clear communication vehicle compared to lead question twenty four b and we know that the strikers located in the wall of the car so i'm sorry why wouldn't there's so there's within that limited range of movement within the plane substantially paralytics surface a user can move the along get member to a position most convenient for him or girl her to push pull while standing and to really get that understanding from looking also at the comments made a three thousand and thirty two dollars in the prosecution history where the whole phrase was discussed and distinguishing the prior not just that language of most convenient to the user so do you agree with my understanding of this limitation or do you have a different understanding of what that limitation as a whole me overcome the prior art but really focused on  the limited movement being within a plane substantially parallel to the pic surface so i don't see the cartoon position either of those limitations of claim one so i don't see how you the any i'm sorry where is any strikers that would allow a device to be in a plane substantially parallel to the  vehicle there's no that that term has been construed consistently by stipulation across all terms that that claim cannot be infringed with respect the claim one you again i believe was judge shane you infringement conventions one was perpendicular one was parallel one was parallel then perpendicular so the notion that there can be infringement of claim one there can't be there is no evidence the record there's certainly no door the vehicle includes the post the pillar the post a pillar defines a lot will surface well if the vehicle includes those elements and there's a lot of services what the device is mounted on if the vehicle includes those elements and they added during prosecution wasn't this notion of just moving to an opposition and it wasn't just moving to a convenient position they decided very very specifically that in light of the birds seen reference which was that device that was pushed into the door jamb that they would add a limitation that requires it to move to an operative position most convenient to use if they narrow not only the operative positions but they narrow das to the most convenient movement what is convenient for a given particular user i i'm not sure if i understand the question but i think that's exactly the point that within that plane of movement when the device used in when it's attached to the vehicle in that plane of movement there is a number of convenient positions that the user can select when pushing or pulling and again i'm a get back to the figures  if there's no mystery as to why hell and focus on figures twelve and six those are the least adjustable figures out of the out of the pat figure nine includes and i'm quoting directly from the past a station column him and means that is a i think a very good example your honor of what it means to be able to select an operative position most convenient to the user when pushing or pulling and i think that's i think that's very well how to claim this without resort to convenience claims twenty two and twenty three while they have other limitations in those claims they speak just to move in the device to an operative position with no mention of convenience so what are we left with here we're left with a very specific limitation that was added during prosecution to overcome prior art and it did in fact overcome that priority we can't just say well hey it was a mistake they should have i added that my reasonable question to you is did you think the district court addressed all of this in its opinion because your original point was you said you were going to walk through the district courts analysis and show why it was correct but i we have to take this limitation for what it is they added this phrase we have to give every word a meeting and it was added to overcome prior art and i think that's the extent i don't have it at my fingertips but that's the extent to which she dealt with wit this was i'm not sure if this came through them through the briefing this device was designed not to infringe dispatch so when it's inserted into the striker it's designed not to move forwards or backwards  now your honor just on i think really just one or two more points on this on the on the on the district court point of the term being subjective again i think it was your honor judge laurie pointed this out l most convenient to the user when pulling or pushing on said handle i agree with you most convenient to use there is not pretty language to see in a claim it's  rather ugly but nevertheless could be trying to get at the thought that there's one position one operative position that's really designed for and more  if that's what the claim is getting at that there's where we're designing some flexibility be able to have some limited movement of the device so that it isn't pushing operative position in the pulling operative position even if that were the case even if there were only two operative positions the push in the polling that still and i and that i think is incorrect it's that's that's not what these claims are about but even if that were true it doesn't mitigate the subjectivity of the claims and i'm not going to i promise i'll not go through the cases again but we require objectivity so the problem with that with that interpretation is that not only would the claims  infringing different ways by different people the claim to be infringed one day by someone who prefers pulling on it and the next they not infringe that person for example injured him or herself but even if that was the case that we're just talking about pushing or pulling that would mitigate the very careful language they chose here but that isn't the case and again i hate to keep repeating myself but going back to figure na that allows an almost unlimited amount infringed how can that be so when this is a device claims and we're not talking about a method that doesn't make sense to me well the way i and again your honor this this claim of is not exactly the model of clarity but the way and i have considered struggle with that very very notion the way i look at it is that that language is a further limitation on really the structure of the securities that it has to be so structured and this is kind of analogous to the ernie ball case has to be structured such that it provides limited movement to a operative position most convenient to the user but not just a limited movement within the plane substantially looking at the phrases the whole and i understand your position to be but you don't know when we say in that range of movement you don't know what is most convenient to be sure is that right so i understand your position to be that those limited movements are not so limited if you look at figures no i and the other embodiments with for example adjustable handles that are in and lesser any questions further questions i think i've eaten up all of my time i thank you your hon there isn't any movement let alone any movement within the plane substantially pirlo to affect surface to have one operative position for pulling and one operative position for pushing  getting back to you and definitely i said your most convenient to use your language i'm more interested in how you would translate that entire final clause that judges still and i've been wondering about starting with means i was looking for something on your briefs and i couldn't quite see a translation can you just give me a one sentence translation of what that final closing my translation of you know whether you're a big guy a small guy a little girl or a big girl it's going to go into the striker and you can pull on or you can push on it and that's about all it's going to do