art that poll shows internal and external seals that record it's complete with several references and external seals padlocks with extra seals would work what difference does it make whether the seal was moved from brochure that it could it's really working together in different order if i understand correctly in other words it's not the it's not the receiver walk but what so both thirty seventy and down or within a few of them endeavor and experience lock designer both thirty seventy and down solve the same problem as wires in the same way and therefore both must be found this relevant in analogous art here the  specification the claims in the prosecution history all support that locks are relevant in analogous r and as both the sundance and the in re would case show the patent controls here and so there is more than substantial evidence to find both the thirty seventy and the down reference to be relevant are within the scope and content of the of the ordinary school of art the person is a locksmith or locksmithing are one thirty seventeen down or in the proper scoping content to the prior art then these patents are invalid because there's explicit motivation plus that motivation and common sense that drives the combination of taking the sleeve from the thirty seventy or down and placing it on the primary references in the thirty seven packaging material and in the thirty seven d price list it describes that the sleeve accommodates different sized aperture as it specifically talks about the shackle fitting a half inch diameter  with the sleeve on a nine thirty seconds inch diameter hole with the sleeve off the thirty seven d was specifically marketed and sold to fit two different size out years we also have expressed motivation in the down the down happened specifically a column three states quote a steel sleeve is provided as an optional feature and quote sleeves of different extra or diameter may be provided for the attachment of trailer towing eyes of different internal dia corporately even if the motivation here which is explicit is somehow disregarded we had pleasant motivation we have common sense a person of ordinary skill me art here is going to be a mechanical engineer an experience lo seven d or the down reference within the scope and content of the prior and there is not substantial evidence to support a foreign thirty seven or doubt is not within the scope and content of the patent specification here r determination of what the jury findings were implicitly the seven and implicit finding that were listed in the order yes you're on the district court here aaron except the implicit jury finds that well on thirty eight fifty one about halfway down before the end of the first part of the opening paragraph he discusses the down pattern and he says at the end of very deal more complexity than just trying to prevent water from slipping down wrong that's it's not that's the principle that we're talking about here but if you if you is that pressing upon the side is going to prevent liquid from going down a wrong i mean that's the principle you have to seal something every word that says a seal you have to do that you have to shift it on a shifting is going to have to create you know somehow see you can there was there's just no way to get around that that's the job still and so that's what you say when you say yes in principle what's what's really lacking in the prior art that would suggest to a jury that this is an obvious slacking in the prior or is the fact that nobody no  of twenty four question and this is forty three fourths of what is there anything more difficult about putting a rubber coated over once it was a horrible as opposed to putting a rubber coating over a power block answered well it would be a little bit but there is no sleeve changing the diameter in the outyears all of those but it is it changes the diameter to accommodate the were opening in the in the eye of the the other member  there has to be a significant amount of play in the odd and the limitations in every one of these claims is that it has to have snogged it you these things will all work in even barnet of carrying a load it will not have unexpected results here you can wire just as shown that you can take this this sleeve that everybody thought was kind of precis to and you can put this on a on a half inch and maybe met a five eight interesting understand no you don't see in the down patton that sleeve in the editor first of all we've never had any discussion about what is an aperture at the trial of the toy an aperture this is something attorneys are making up talks about a lot mentions the word six times and it talks about having a lock mechanism in column two of the pattern it talks about any any convenient locking mechanism can be useful down was intended to be used with a lock mechanism so therefore it does have a lock manner so everybody knew that when you built this it had to fit in the hold and so there's nothing new about the fact that it was close to the only thing missing was the teaching of the use of asleep to accommodate a larger open exactly which is 's the first thing second down clearly teaches us although derek's leave that bear the load so there can't be any basis for expected results and the teaching away hasn't been argued until now but the teaching away same here is the only expected result