thank you and good morning may appease the court would like to begin by addressing the significance of the supreme court's decision and boss doctor says clayton county the supreme court's decision  clear that broad inclusive words are not ambiguous they simply demonstrate the breadth of a legislative command the court made it clear that if the words of the statute are unambiguous the courts must not consider legislative history or other extra textural considerations and the court warned that proposed interpretations of the statute based on extra textual considerations are sometimes suggested in an effort to persons and really appreciate the granger and the beauty of the canyon and mars or canyon person so i want to return to the united states to see the grand canyon in person person says i want to return to citizen flies from mexico to paradise but over the grand canyon in arizona a plane flies low enough that the person can see quite clearly what the canyon looks like the person says i want to return to the united states to see the grand canyon in person is that a frivolous use of the word i don't think flying all over the united states would i think that there i think the factual context of the person's prior presence in the united states and subsequent return is relevant it's necessary to understand whether or not there was a return but i don't think that makes the word ambiguous just apply the  i but i don't think that makes the word returned i think it means you need to know what the person in terms of i guess what you're saying this is the person who flew over the grand canyon did he go to the united states and did he go back when he returned to the grand canyon i suppose in that sense  you need to the word if you will the plain meaning of ambiguous free means to go to and to go back i mean to go back to some place you've been before i think  they require that the vaccine be made by the vaccine manufacturer located in the united states and the person returned to the united states within six months i don't there is nothing the plain meaning of the word returned the plain meaning of the word go back to there's no reason to suggest even if the word returned were ambiguous that it means that we wire previously living in the place that you returned that's a complete that's an addition it's a material important substantial addition to the requirement that  in the plain meaning of the work so you go back to your to your trip to the grand canyon so if the person from mexico landed at the grand canyon in the united states at one point and then the subsequent trip he had returned to that there's nothing even if there were some ambiguity in the term returns there is nothing doesn't really frame the issue in this case because it's not a matter of whether i was travelling over the grand canyon and returned stolen i had the blessing of being pregnant and number of times the question in this case united states is a child in general was legally sufficient to make his subsequent entry into the united states every term and on that point it really shouldn't matter whether we call the child and you are all a child in utero or a fetus or accumulation of cells there was a presence of physical presence in the united states by the child in the rol whatever words you used to identify and that that occurred and it has been legally recognized that the existence of a child led to the statutory revision as informing what the decision here on the question of st impression i understand your argument yes it is a question of st impression  the question of whether the presence of a child in utero in the united states is sufficient to make a subsequent entry into the united states  which the word is used the court to block word hear the word return out of its contact and apply a dictionary definition to that term in the abstract but rather to consider the term meant that of the extraterritorial application so it's very narrow in the sense that it requires the individual to be both a citizen and addition to be a federal employee or member of the armed services and the reason i bring that up is because that narrow language it would be inconsistent to read the following section subsection three in its broadest sense in the way the petitioners are indicating if the immediately preceding section is so narrow that's one way in which the context dictates that some firemen care nothing but an additional point weighing in and favor of respon that was dealing with the french citizen who has backed unaided who visited the united states returned to france and was vaccinated there and then a week later returned to the united states only to transfer plans on the way to mexico but under petitioner's view of this case that individual would be qualified to pursue a climate of the vaccine i think that's an absurd result cannot just switch to switch gears a little and i guess i'm looking right now with that provision you cited aged twelve red and that's on the question of children in utero whether children in ut know talking about now ok what's your argument about that i mean this provision that titian is rely on talk about maternal immunization i know it's a different thing but how do you differentiate what's petitioners argument that the vaccine act ikes to territorially and that specific instance when there is no express language some author of that but there is otherwise there is no expressive language then there's the eight of title wine at definition presence which is our argument as well and he also indicated that it's not necessary to re evaluate the definition of the word person which we also agree with that remain a grounds for extraterritorial application of the act so that's just further reason to support our position it would have been quite easy for telling us to deal with that issue go ahead correct yes that's correct well except that when congress dealt with that we're saying this is a question of st impression so in fairness this wasn't an issue that they would have been necessarily aware of this because there had been cases yet decid that involved raises this question right that i'm not sure what congress was aware of course but yes it's true that this is an issue of st impression so it's possible congress wasn't aware of it but it's also possible that congress was aware of it and that congress it intentionally omit that language and we're left with what the language as of is provided by congress and that language does not provide any or your side but beyond that i'm not sure what else to make of it frankly you have to have had a real presence in the united states before you left you have to live there because the government does the government stand by that interpretation of the gallery yes to the extent that there needs to be some type of residency established but no in the sense that mcgowan was fairly rigid and said and requiring  return necessarily implies that you have to have been somewhere in order to return to it in this case the gloss on return is good on the degree of  and if you look at the facts that we have here the role of the two and the roman three the roman to produce deals with military and governmental personnel that have temporarily gone abroad those persons presumably had some presence in the united states before they left and one might interpret roman three to having similar requirements for purposes of how long you had been in the united states before you left to go abroad yes and to to the extent that my gowan and the contacts provided around the subsection in this particular subsection indicate that we also agree it's it's we're relying heavily on the statutory context in which the word returned as you to figure out what the meaning of that word as and it does include some type of residency prior to receiving the vaccine wasn't for a long enough period time to qualify to satisfy my gal and yes that's correct the court has any further questions i would be happy to answer those anything for the colleagues i think we're done thank you very much thank you very much ok mr web the whole purpose of that as opposed to section twelve dollars is to provide access to the program to people who don't have a prior presidents who haven't previously lived in the united states the whole the definition of person that's from  and the very end of it says section c of that nothing in the section shall be construed to affirm the line expand or contract and the legal status or legal rights applicable the question of whether that person received the vaccine but they assumed essentially that challenge was a person for the purposes of vaccine that and so