i have three points that i'd like to make this morning the first is that the words decision was fundamentally flawed because they refused to interpret the term field t field has a very specific and defined use and to not accorded that definition tainted the rest of the board's decision the second point i'd like to make has to do with the board's finding that all of the hardware and software components used in the claim systems were generic to reach that conclusion the board had to ignore the express disclosure in these patents that this is the claim system's use specialized eight i c software that is installed on all of the hardware components and when that's accomplished you have a specialized system it's not a generic system and finally from the very first we have certainty that these are not covered business  patterns and we believe that the court's recent decisions and on wired and secured access strongly support our position attention to the specification and the terms the ins is used at a number of times but i think probably the clearest definition is provided at scan thirteen starting at lines forty and that's the appendix zero one two five and a short section it will be appreciated that the pack form which displayed on the computer in these boxes they are entered so as to fill of quote fields and quote a delimited alpha numeric character string being a quote field unquote the information  by the characters can be transferred to and used in completing other fields in related documents is clear disclosure that the applican defining fields directly as a delimited alphanumeric characters string and not the way the board seemed to use it in this decision as just the boxes that you see perceive this human is not perceived that way by a computer so there is a delimiter and that's essentially a label and that identifies what the expected information is going to be and fields on a paper form certainly not but we did invent fields as they're used in this application you were the first one to invent a computer feels the first one in in the applications where  lawrence force when agencies your universities had legacy mainframe computers the problem with legacy mainframe computers just they're great for storing information but they had short hours you could not display an attachment such as an x ray or fingerprints or photographs on a mainframe it does not work i appreciate the importance of this issue i'd like for you to address  issues and certainly the one on one issue well we think your honor that they are tied together because not by  failing to interpret fields as being a separate you know unique component to this invention i get that but apart from the construction their claim construction let's go right to  why are these claims are these claims directed to or not directed to an africa idea you know we don't think they're directed to an abstract idea your honor and the abstract idea  because the board focused on an abstract idea affectively moving data but that really wasn't the point because data was already being moved we'd knowledge in the background that insurance companies had already developed systems where you standardized forms including just the information like name address could be submitted to directly to the mainframe the real question here seems to be whether it's an innovative concept in step two of perform that is correct there is limited description and that would be an issue for a program but once you're on your private with a detailed explanation of what needs to be done that's a relatively contained the claims don't provide that direction the claims do not provide that direction they they claim they directly claim the systems and method not not true in terms of functionality not exactly the claims they claim are directed to the function correct that's receive the form that has the actual information about the patient procedures that are from the mainframe it may have or it's already been submitted by the dentist but he cannot pull up the supporting documentation such as an x i believe your honor has put your finger on it there were issues involving the alice tissue both your arms and the curtains at issue here do not describe any detail of the day i see specialized software you are not actually stating in the past that existing commercial software could be used such as lotus notes java lives and also recognizing ok all right well do you believe in this case that the patent office decided that this patent presented a claim that was directed to the financial industry in a manner that is consistent with unwired planet and secure access to much recent cases that have come out of our own yes i believe that some walk me through how it did that because you no doubt know that if you use the same language that we said and apply the articulated the longstanding because it articulated the extent to stupid but in actually determining whether this was a financial product or service i don't see that the use that incidental to language they fifty seventeen they used the right standard what claim are there dressing up page seventeen ok so if we turn to it to they are addressing all the claims that were challenged and they know the word how do we know that ok so if we go to the middle of the paragraph on seventeen for the paragraph that says accordingly if you go down to the to middle bottom where it says we must agree with the titian or that the challenge claims not just claims eleven and thirty claiming a corresponding being that it says where it says apologize for financial related activities and ever saw it and then it says and the activities that are financial in nature and civil to all financial activity or complement are to financial activity the preceding pages understand secure access to stand for the proposition that the financial aspects must be present in the claim it's not enough for a general claim it could be used in many different fields identification of a financial service or product however when you were view that in all talk about the in the claims eleven thirty that specifically call out insurance claim forms  a bunch of fields you know and so that clearly is not a financial product or related to the financial industry it might be electronic system capable e used in those places but on its face that claim has not a crown i understand what you're saying  service the you let enough you look to the specification to see what type of what is this data processing for this data processing is if you look at these patents they are got the standard all wrong and articulated the run standard when i don't understand is your defense of claim one after secure access i am baffled and i know you're absolutely right you only need one claim and then it's a c b s the whole thing and peter has the right to look at every claim in it but i'm baffled at how you can defend claim one after secure access and just so you know i have to meet my car pool every board decision that's been decided post on our planet and secure access and every one of them say these cases stand for the proposition that the claim itself must have language in it tying it to a financial industry which is great for you with claims eleven and thirty don't get me wrong but not for climate and i just i guess i just want to be clear about what you're arguing something you are as we're being told we're  is it a pattern that claims the method for data processing that is yours we have a claim for a method of data processing that's clearly want and then we look to the specification for how they claim it's being used or but the fact that you can use a program a computer program in banking that's not enough well because at the end of the day almost every computer program can be said to be using the services but when i read secure access i started thinking to myself is the court attempting to articulate explain in scale if you have a point say you have a point that you know so far there's been about one hundred forty decisions by the  various references to what i view as to be the financial service of the nets the insurance industry and you get shamed by those claims the thing claim made the claim twenty one reference to  insurance services claim one does not i mean i would still submit that interviewing c v s under the definition of a patent for a claim for directed to a method for data processing or it's for data processing and it's you in the management of a financial product or service i don't think that the statute specifically wires that the data processing claim itself your actions and and if you do have a pattern that is predominately and is primarily directed to financial product or service that's what i believe congress is attempting to has already determined that the words of the statute that include quote a patent that claims means i mean the judge player could not have laid this out any more clearly at least has the question is is it enough i don't i just don't see any ambiguity in there for this notion that the specification can tell you what a generic claim that could be used in any industry is really meant to be used for the patentee i'm just really at a loss for how you can justify your argument in light of secure access your argument is the dissent in secure access it's a well written dissent it makes compelling points but it's as clear as the dissent your argument it is clearly on all fours at the d enough wood for a life like i really go back to the statue i was working at a data processing not a light bulb but we've got a data processing way that is used in a financial product or service and i understand what what we have  i just want to go back to the final decision and if you look at the appendix zero zero five three the bottom of the page you'll see under the caption cancel you claim thirty six the board notes that in the institution decision we determined that the zero two zero patent includes at least one claim directed toward activities that are incidental or complimentary to a financial activity and highlight a claim thirty six as such a claim in response we move to cancel claim thirty six and in the other patent claims eleven and thirty and that was granted if we go to work aboard carol and i'm not sure this is wrong you've got to provide standard that's the longer useable i suppose we were to reject your contention that we shouldn't consider these claims that you surrender suppose we agree with  underlying invention doesn't change so you are the invention was described in terms of an insurance company and there's no way to get around that but it was also noted that the the invention was not confined to insurance companies because it wasn't really related to insurance it was about transmitting it displaying dad at the couldn't be transmitted and displayed in this way previously but still so you're saying we don't look to the individual plan well we have to look to the year what's behind the claim and that's the invention itself so your honor one of the other alternative uses was a normal force so i suggest nervous answer starts next question his question is if a letter thirty or in which don't talk about law enforcement thinks pressley talk about insurance claims those claims are limited to insurance claims and this question to you is if a letter had thirty or in all claims expressed that limit themselves to insurance claims why been directed to the use of law enforcement i don't think we'd be here but the invention itself is