the video signal the third area is that the t v only works in analog conversion can i ask you because you just focused on three things and i have a question about something you didn't card so excluding other things like printer port on the assumptions you didn't mention if you want to get back to the other things suppose i were to agree that the court of the district court were give it up or yes we want the opportunity so it's going to have certain yes we would like the opportunity to play now i'm really confused because you know i understand your debate with the other side up of three terms that you don't raise even though they were arguably compassed within the stipulation so put aside that portion of the stipulation you concede that seven of the terms are determined to have is that what you said that is that is correct right so if we affirm on any used to feel a bit to one and only one thing given all of the claimed constructions you have no interest in a case that you have not stipulated to the absence of intrenchments if you change any one piece of it well concerning the analog conversion and it does not solve the problem of to a communication so if for instance if this court only rules up ported source was improperly construed that solves the issue  a communication and that also does not solve the problem of whether or not the t v a works in julie digital environments so if there's a way to construe ported source that would solve those problems then absolutely then we then we'd still be able to make our infringement case if we solve the ported source term so getting getting back to the three fundamental issues in the district court circumstances it actually read it in limitations from deep in it claims back into the independent claims for example claims nine is the only independent claim that when you read the construction that is correct our concern is you are correct in that it is pertaining to the video signal very very clear that mr weber in the prosecution and are concerned with the district court's reading of a bottom is you know our concern is that the going to provide for no interactivity and we're a very worried down the road for a lack of written description probably because it's news you remove all interactivity within the circuit to the invention doesn't work you need to have some sort of acknowledgement signals that go backwards coming from and that's where he gets answer the question i took at that just correct me if i'm wrong that the way this debate was shaping up was that if you distinguish different kinds of signal understood as i understood it and i think you agreed to me what can't be bi directional is only video signal movement not the other stuff that in pointing to the handshaking just doesn't  isn't a ground for disagreeing with the district's claim construction i guess that it doesn't preclude bi directional and kicking and shifting that is correct and so i think the main bone of contention that we have with this construction the non interactive leak that's what we're sort of focused on and i understand that it goes on to qualify that of the process video signal but given the other errors made in that construction where whatsoever so you're correct in that yes the video signal does not go backwards that's a lot of webber that clearly describes and taking signals and interactivity and timing throughout throughout the three and i pad so the believe that's a proper distinction from from about about our issue again was the notion of interactivity but again the biggest problem is the notion that microprocessor based motherboard are so he understood what exactly he was doing what he was able to demonstrate in order to provide you know some sort of support for this method is look i have these components i can assemble them in such a way that they are that they operate functionally distinct from the main computer but he makes it very very clear throughout the patent and in the claims and self that this is a method that can be used in such a way so long stephen smith on behalf of the intended appellants and your honor i'd like to begin with respect to your question about which of the clintons are dispositive before your honor i think secure access makes quite clear on page six of their reply brief that's quote ambiguous and they never say anything like that in the stipulation or anywhere else that's going to be a waiver of their right to win and say six of the seven if they lose on monday no i understand that your honor i think that's one language we we look at it differently but more to the point though if we step back and actually look at the claim constructions with the district court went through here we have a very you know a fairly uncommon situation can you address the ported source one which is if i something claim i want and claimed want to speak specifically about processing computer program data into a portrait source of display ready first process video data signal i'm reading  card your honor and this is just a specification say you can get this from those places only and from nowhere else like the printer port the processed port and sorts of the splay ready first process video data signal yes so the ported source here your honor is limited to the processed video data signal as opposed to where there's dependent claims that talk about the issue of printer data and that that's the distinction anuradha moving to the term t v a which is the central dispute one of the central disputes between the parties here today this is a relatively uncommon situation where we have a coin term as no plain ordinary meaning the inventor himself prosecuted and wrote this patent and he left no doubt with the t v it was and there were several components to that first that it was an accessory device added to an existing computer and this is a very central point of the of the invention for t v yet and that is the there is to embody that that really give life and breath to yes that's figure sixteen and seventeen  inventor mounted them the t v that operate absolutely independently from many hardware configurations for example apple or i b m wanted the t v to operate independently from memory any operating system is where the inventor himself coined the term there's no dispute that it's a coin term and as your honour's we're my mail in the goldenberg case stands for the proposition that where you point a term we have to look to the specifications of life and full force and effect to the to that definition and critically here i think goldenberg has a brief conversation a brief explanation that we're it is a coin term it is incumbent if there's a requirement on the accessing the t v input port through the computers printer data signal how court could port and then what's happening there is that something that is about to be a video signal that's displayed is coming out the correct right so how is that printer port not accorded source oh it's not approach i understand your point your honor it's it is a it is a source of printer but it's not a portrait source of as the claim requires display ready ready first process video signal so it's a printer data and if we see that claims one thousand and twenty for example they talk about the data is ascii or binary it's in a different format coming out of a printer port than it is coming out of a video input port so the distinction between in their metric clear but there is a distinction between the different kinds of data coming through so your honor for example claim eight absolutely you could have the t v up to the printer port absolutely we're not making that argument that you cannot we're saying with respect to claim wanted talks about the process video data and if we look at the the specifications it's in in a poor when they when the when the inventors talking about ported sources of or sources of printer data they make clear that figures twelve or thirteen for example serial and parallel print ports and it's a different kind of data coming out and therefore different kind of hardware is necessary and different kind of functionality is necessary as well record reviewed every single one of the arguments that secure made and address those in detail fashion in a well reasoned opinion and the issue we wanted to raise on poor the portraiture honors very straightforward and that is that the trying to do is to construe the term in isolation till which would be very broad and would be inappropriate given the specific claim language and so we think that district court was right addressing this issue how they did  the record we believe are absolutely correct and therefore we think that district work across the board on every term was was accurate and did not commit error and unless there is any more questions or i will see the remaining amount of my  smith's last point concerning the poor terms he's absolutely right that port is never used in isolation but it's a bit of a cute argument to say that never use an argument it's never used in isolation because he's essentially taking the surrounding language around pork and trying to reconstruct pork to complicate the reading  the t v s so our position was and is fairly plain broad reading of the term port because it is surrounded by modifying adjectives and modifying words so poor can be m if we are to take the district court's construction on t v as it is that's going to read out claiming that's going to ignore the fact that the t s a can accept fifteen is the printer of course the a gateway through which process video signals are moving or some other kind of signal which i took it to be your friend's  explanation for why the claim they really doesn't undermine the district court's claim construction limiting the ford source to a video that your graphics accelerator card means you've hit the issue processed video data signal is described in claim one and the process video data signal which it would have to claim which was going on in cleaning what signal is moving through the computers printe signal or not yes it is how do we know that because i took it to get your friend on the opposite side was his as i mentor standing and i could be misunderstanding it was answering my question about cleaning it by saying different signal so it doesn't matter that the different signal is coming out of something other than the video adapter graphics accel write your card because the clean construction applies only to the video the first process video or the process