thank you your honor may please the court of coventry here on behalf of jericho systems corporation the first sentence of the summary of the a three six patent makes clear that the invention is directed to a system to maintain  security access policies that substantially eliminated many of the problems in the prior art computer based security access control systems in the first sentence might might be fun but why though we look at the language of the  we got the claims just outlining mental steps with computer reading now here i don't think that they are just adding a generic computer to mental steps the claims themselves as you know go through a very detailed step the series of steps that provide an improvement over prior art computer based access control systems so this is an example where you're dealing with somebody saying for a first time you know would be great if we implemented security policies for the computer and you should just use a computer to do this abstract idea what we have here is we were dealing with problems of fire our computerized i've been there computer of a security access systems and there are specific concrete problems that need to be resolved related to  problem is in the field that this cooling solves for thing one there are several problems there your honor one of which had to do with trying to resolve issues related to bend with processing power so what the system does this instead of going out  steps here your honor that changed the way that computer based access control systems work it evolved among other things separating the server from the user so that there's no way for the user to corrupt anything that's done in the request so instead of having all the rules present at the server it goes out and retrieve the specific role once it knows what is being requested to be done and the benefit of that among other things is it make sure that we're not using still rules you know one other thing that i in your system on the server i'm sorry i think there's a little bit of confusion what i was talking about earlier then i was talking about whether or not the actual use user actions were present at the server user attributes as opposed to the rules like i said because so those are two different things of course to solving the problems of the prior art computer based systems one of which was reducing the processing power and reducing the van with that required for the system another one was you're making sure that there is improved security measures such as preventing the user from having access to the rules using a computer or the pad no your honor i mean first of all i'm just focusing on the one specific element you were talking about there but the difference between looking at a filing cabinet for i guess examining whether or not an attribute  value is present it would be several things first of all there are the good user or in that circumstance would have access to the information that has to be used to decide whether or not the actually value is present and would also be able to then possibly corrupt that information that young when it comes to mind right now your honor i do want to charge briefly on a couple of what's an abstract idea this is present and the algorithms are used and i think we've been have which is deemed to be a special purpose computer for purposes of the federal circuits pressure on the distinction between special purpose computer vs general computer these claims are not implemented on a general purpose computer we don't have a general purpose computer here in fact a district court even concluded that we met the machine transformation test as a result of that first week we've had a number of one of one cases in which you could make the same contention that people have unsuccessfully where you've had a computer which has been transformed if you will as per your going into a specific designated dedicated computer by virtue of the program and its been done to it but none the less the court is that well this is still an abstract idea and one could say the same thing i guess about alice well your honor i think that you're right of course many people try this because it is outcome determinative i believe specificity just vital in our claims are claims fell out of very detailed set of algorithms that the court that the process goes through in order to decide whether or not to allow access to a particular specimen just to be get away from abstract yes that's you in precise detail step by step what the computer does and it doesn't just say you should figure out whether or not this person should be granted access and use a computer to figure it out it says first step one two three four five with very specific detail district court took these very precise claims and boil them down to people who meet certain certain characteristics are entitled to do certain things that is completely divorced from the entire purpose of this is it because that that's too simplistic that's that's one of say that they are cover attempts to solve problems associated with computer based access control systems by using what we describe as a dynamic enrichment process to avoid problems related to bend with processing power and security rule you determine what information is required to process that rule one start you have the list of vital required actually used to determine whether or not you have those actually it's already available on the server if you don't have those attributes already available the server  series of connected requests based upon which connectors have which information received the information back from the connectors and then evaluate the rule based on the information retrieved from the connectors return a decision about whether or not actually should be granted would you agree that if if you set aside those limitations that deal with the connectors and the non server databases that are that may contain attributes of a rule  with the distributed aspect of this access system that is to say the connectors to the non server database for purposes of that tributes and rule if you take those out you simply say everything resides in the server is there still a patentable invention in this case you know that's a tough one for me to answer your honor x because it's so divorced from the entire purpose of this invention but of well it's a good starting point for minds way of thinking about this case because i want to know of weather and how much you're relying on those just distributed aspects of the claim to get you out from under one a one well i think that those are important aspects for getting us out from under one one hundred one in part because it makes it something that can't really be done by hand or body can you think of a reason i only put it this way can you think of a reason that the claim that i described without the distribut and that's just flatly incorrect and that this court case law this court has done it again and again in the baltimore for case where there are eleven steps and accenture where there are numerous components for you my staff including i might add components almost identical to the ones we back to the claim in this case i think that's where as just laurie mentioned that's where we should start and so looking at this but isn't that a problem because everything boils down to an africa idea disappointing at somewhat we yes so abstraction involved in those cases so when you're looking however at something that can be done mentally and i think it's very clear when you look at the steps here they're claimed contrary to my friend's suggestion not with any specificity but at a very broad love if you look at what the steps are here they boil down to fox basically first receive the request for access second consult the rule for access third determine what information you need to evaluate the rule fourth go out and get whatever information you don't already have and fifth apply the rule to the information and make the access decision that's exactly what anyone entering a secure building for example has to go through that's what i went through today coming in the a none of these protectable like patton's well in by say if this court said that even if ideas are round breaking brilliant they still if they're abstract don't first it looked at whether the claims as provided had a real world an along and look for a brick and mortar and along and in that case you didn't find one because the claims were directed at the problem of being instantaneously transporte brick and mortar analog to connect it to common human experience so for example in this case the common human experience is going through a security check are we talking about implementation of an idea itself it never mention the machine or transformation test so what may be including some situations it's certainly inconsistently looked to not sure i'm satisfied with your and maybe you haven't finished your discussion here along with the other catalogs of all related stores do you stay here just look at the level that's a brick and mortar and all it is in the court actually considered that specific analog and decided it it wasn't like the coins in the following respect because the claims prevented you from being instantaneously transported to go completely different location and it talked about that situation as still being in the store that you were originally so i didn't provide a close enough and along so that's the first reason that d d r is different to  if that directed to the specific problem on the internet and we didn't have this privacy data but target and the federal government disclosures by hacking none of that existed before the the computer this patent appears to be directed towards those type of problems isn't that specific so similar to the viewer you're on and first i would point out that none of those characteristics that you just mentioned and that my friend is relied on are actually in the plans when you look at the claims the claims were down to very simple set of steps for achieving access control the same steps that you would apply in the real world and so for that reason alone d d r has no applicability and i would turn to the intellectual ventures case that this court decided last year where it reached the same conclusion there you had claims for customizing internet web pages by taking user data user browsing history combining it customising in creating a brand new web page something that was purportedly never done before in that case i think and the court realized that there was a real world analog there and so therefore d d r doesn't apply so we know d d r only a pos if there isn't a real world an one reason this is different but if your goes on to have additional requirements it must also in that case it change the internet in a fundamental way in a way that hadn't been done before so it wasn't just changing something done on the internet or on a if you would the argument that you're posing counsel spent most of his time on this morning which is he parking if you will of the attributes or of the rules attribute based access certainly to response you first of all that is just a commonplace outgrowth of the abstract idea itself you can imagine somebody to send how do we know that i think you turn to the common experience that the court look to at the boss's workplace and saying i would like to see the boss the secretary assistant calls the boss and says are you seeing visitors today and the boss might say only family members so there's the rule the assistants retrieve the rule now the system is going to apply the rule to decide whether to give the person access so there are many other examples exactly like that and i would point also number two more specifically to this court's decision in the center there you had specific components organiz a specific way that i submit are indistinguishable from the way the servers organized here in that case there was a server there was a separate database it was called a task library database that held the rules separate from the server the server when i received information from the user which was also separate will then go retrieve the rule from the task fiber a database apply the rule to the characteristics of the information that's what this court said and then generate output back to the use clarify if i could your honor the way accenture addressed those components in that case was under the rubric of whether they were just generic computer components performing generic computer function and so those are the exact same function i see so you're saying those functions are the accenture as defined those functions in sectors generic computer functions for purposes of any kind of computer related precisely your honor and that's exactly if you look at all the things that they're relying on every single one falls under that same rubric as general computer components performing general computer functions things that the supreme court has repeatedly particularly in alice found not inventive not enough to add an inventive concept and this court  cases since alice has held the exact same thing the exact same type of components the exact same type of ideas your honors i'd like to try to squeeze in three quick points if i may the first is i think judge bryson asked a very important question about how do we know that these things are supposedly commonplace idea that this was decided on a motion for judgment on the pleadings  there is no support for the notion that it was commonplace for access control systems to store some of the information regarding rules an attribute away from the server and for that reason i think reversals appropriate does it matter in this case for granting a one to one motion we identified i think a couple times in our briefs that if for example they were going to argue that the word of the steps did not matter that that's a clean construction issue that i think would well if we're stripping the claims of so much meeting that patents directed at solving problems and actually base actual security systems are at the same abstract idea as using advertising as a form of currency on the internet then we have really