of the fibers remain the same but that all the fiber colors of the fibers remain the same and the words overbroad construction of the term optical interconnection module renders that term devoid of sensible meaning because under the board's construction any device that has an optical fiber cable plugged into it somewhere would be treated as an optical interconnection module that display defies common sense and it  divorced from the description of an optical interconnection modules d found in the specification as well as the meaning found in the technical dictionary used in this field as well as the very purpose of the penned in eventually which is to make it help me understand which would connect two screens cable together right that's right principle or edge of stake the purpose of having a module can vary from system to system sometimes it is to to break out the fibers into individual fiber sometimes as here is to do pairwise flipping but yes you have a module that serves where the module itself is doing the optical interconnecting between systems ok but you also can have a m fiber optic needs to be connected to an electrical device such as a computer right you can have you could have one module next to one computer and then a fiber optic connection to another module which  connected to another computer right well you could have a you could have a module if you're going to have an optical interjection module then the module itself needs to be optically interconnecting systems technology you know that could be one that could be a function of the module connecting to an electrical device right so it's have the optical cable coming in to the module and then it connects at the other end to the electoral  as a housing that holds a fiber optics places fiber optic connectors and fiber optic couplers used to distribute signals on incoming fiber optic cables to outgoing fiber optic cables by means of connectors and indeed every single example that you find in the specification every picture every every description is one that is consistently using modules that are connecting optical ribbons and optical fiber connectors by an optical path that i agree at the end of the system you have to have something other than optical interconnection modules in order to be able to do an optical to electrical transition and that is what i can berger is disclosing but as the testimony from from our expert for example appendix six hundred and twenty eight dollars mr pearson explains optical interconnection modules are modules that are going to be found in the middle of a network and the whole point of this invention is to maintain agree that is the that is the question and it really boils down to the boards the boards overbroad claim construction and i say it's overbroad because under the board's construction any device that has an optical fiber plugged into it is going to having to have an some optical inner connection somewhere with it at our point our consistent point but from from institution and in our panel the response is that it's the module itself that has to do the optical interconnecting it's not enough that there is one or even several optical air connections inside the module it is that the module itself has to do the optical interconnecting and i realize now i sure with that well let me offer an analogy and i realize analogies can be can be dangerous but but let me just try one imagine what you might think of as an electrical interconnection model what would be in a classic electrical  interconnection model a power strip right you have the plug on one end in order to go into the wall socket or into an extension cord or or whatever you then have the strip itself that distributes electricity to different outlets and those things themselves can then have an electrical connection to it that would be an electrical interconnection module but the book the but to use the to take the analogy one step further what the way the board's done its construction here is it would say any device that has an electrical connection in our case is up the goal for my hypothetical electrical would be intimate electrical interconnection device so like television a toaster would meet the the definition of electrical interconnection mod under under my hypothetical if you use the ports approach that here take i don't think that's true i understand the board say it had to have two modules have to be connected optically and at the other end they can connected to something electric well what the board is saying and i think if you look at appendix ten excuse me at appendix nineteen the board says quote i can berger describes fibers with an optical head forty optically interconnecting two fibers from the ribbon therefore i can berger teaches a module that forms an optical inner connection in the quote so what it's saying is that you take i can berger module ten which has the connector forty and when when when you plug the optical ribbon or into forty that's making an optical inner connection and that's what makes module ten of i converter according to the board optical interconnection model and that would be true whether it was plugged into a transceiver which is what i can burger is or if it was plugged into a cable box or was plugged into anything and that's what makes the definition here fundamentally overbroad and again they have no answer d pan to what has no answer to the standard dictionary definition other than to in the figures and so forth and you so far talked about a dictionary and talked about i think some expert testimony so we are in the specification to support your constructor it seems to me we're just in line drawing here about what is actually a m right what we what is an optical interconnection module and i don't mean to quibble it's just that the modifier optical inner connection goes to what the module is doing what the module what the module is and i would say every single example if you look at the abstract which every single example and there are multiple examples in the detailed description as well like on column three lines thirty two dollars to thirty five dollars every single example describes modules that it are connecting optical ribbons on one end and optical fiber connectors on the other and the only thing that they say in response is oh well those optical fiber connectors don't actually have in the illustrations the fiber plugged into them and that's because the term optical interconnection models just being used in its plain ordinary sense you don't need to show that it's beam that the fibers are actually plugged in if it's sitting on a shelf and there are no fibers that are plugged into it it's still an optical interconnection model every single example has optical fiber connectors on one end and the connector for the optical ribbon on the other which means it's an optical ribbon coming in on one end and it is optical fibers going out on the other nursing your toaster analogy  model right so it's not just going in and requires a connection within the model some sort of i agree with that just well it's a maybe the toaster analogy doesn't work maybe the better analogy is the is is the television where you got to put the plug into the back of the television but i think that is exactly the same as putting the optical fiber plug into a connector forty of module ten of of  disagree so i think what council is overlooking is that the board's destruction was in two parts it requires an optical connection with within the module that's the st part that's at eight hundred and ten but it also of course requires an optical interconnection claims and then we can look at the spec and it lines forty nine through fifty one in column two the specification says the module sixty also includes an optical interconnection section having an optical connector and if we go a little the nd part of that is that the optical connection within the module part if you look at the specification figure two for example and column from three lines two thousand three hundred and twenty four that reinforces that concept but here's the important part understand claim three is very different from claim one claim three has to do with optical assemblies and what claim three is concerned about is the maintaining polarity the wiring between the st module in the nd module on opposite ends that's a crucial distinction that is the purpose of the invention there's a lot of discussion about the purpose of the invention which i'll get to but that is the purpose is maintaining polarity and in fact that's exactly what we saw and i concur in fact both parties seem to agree on that particular point i can berger and the patent is concern and claim three is concerned about maintaining polarity that's why the murder is so on point here so let's talk a little about their construction so optical interconnection module must connect incoming optical fiber to an upcoming optical fiber so here's the problem with that there is simply no basis for that in the specification of the claims if you look at the plain plain language there's nothing about outgoing fires if you look at the figures in the specification there's no discussion about outgoing fires in fact that's what compelled them in their briefing before the board to add in optical fibers on it coming out of the modules both below and even in the br that it has to be an outgoing optical fiber connection if the claim is agnostic to that claim three doesn't discuss then just like you picked up on this exactly ultimately there is some sort of electrical device it could be a computer server a computer server computers remember this is in a lan with their argument is that it has to be outgoing optical fibers so in other words this these two modules with the stuff in the middle they can connect all sorts of things it just doesn't have to be outgoing optical fibers that they're connected to they can be connected to a variety of different things as just i point out they could be electrical in nature they could be out to electronic in nature they could be fiber optic in nature the claim just on the bit in the way they want them to be limited and that's how they're trying to get around i can berger and that's why they change their construction in the pan or response to pattern response because that issue this claim just aren't limited like that and with respect to their extrinsic evidence that's just a bit of a red herring because that explains it governance is in tension with what the patent actually discloses i claim claim because remember it in and claim three we're focusing on what's going on between the modules we're not focusing on what's extra mile beyond those modules outside of the optical assembly so that's a that's a crucial modules inside the assembly the concern is that extra all that extra money and cern claims are agnostic to that and that's a big distinction from claim one where you're really focusing very directly on what's going on inside the your honour's would we need to focus on the claims that issued not the claims that corning which is that issued the intrinsic evidence is devoid of any support for requiring the six for the optical interconnection modules to connect to any board's construction of this limitation lastly i think it should be emphasized that as a factual matter it according has conceded that i can berger does indeed disclose an optical inner connection and this is what corning stated to be sure there was an optical interconnection at the point where the fibers of the optical head body forty are connected to the separate fibers of connector sixty four and i drove the court's attention to a three hundred and sixteen so no matter how corning thank you just well i think the question that you were asking is exactly the right question here because there is no purpose to maintaining polarity in something like i can work because what is coming out of i can burger are not optical signals what's coming out of i can burger our electrical signals you start to maintain aware and do you know in dealing with for example the diodes that were discussed by your opposing him so inside i can berger yes there there are there are fiber optic cables or fiber optical fibers that are connected to the very to the various  diodes one for transmitting one for receiving but in terms of what is coming out of i can berger itself if you have the optical signals coming out on one end you have the electrical signals coming out on the other that's what makes it not an optical interconnection module it is an electro optical interconnection i don't dispute that it's interconnecting something what it is interconnecting our electrical signals and optical signals in order to be an optical  interconnection module it needs to be in or connecting optical signals because the entire purpose if you look at column three lines thirty two to thirty five the entire purpose is that you can use the modules of the present maintained from one to the other there's nothing special about having the ribbon run between two models what special is being able to have a series of this these where where the color remains the invention will that is good evidence for how the claims are to be interpreted and fundamentally they they have no answer to the fact that the the only technical dictionary definition it issues here makes it clear that you've got to have the incoming and outgoing fiber optics or the capability for again if you have the device sitting on a shelf it's still an optical it's still an optical interconnection module other than to say well that somehow inconsistent with  every single figure figure to three and for every single one show that is that the module itself is used for optically interconnecting of optical ribbon on one end and optical fibers on the other that's what it means for it to be an optical interconnection module and as for the point the my colleague made at the very end regarding forty dollars sixty four cents that was not a basis for the board's institution it's not a