wrenches and also in some of the trade manuals terms that were used to find flat ranges but it doesn't cover the whole complement of tools that are ranches heading eight to a four is an a or nominee provision so it defines a class of articles and absent contrary legislative intent limitation or exclusion wrenches in heading eighty two or four is meant to cover the entire complement of wrenches or tools commonly commercially known as wrenches there's one limitation and having  are not designed to hold or turn twist they're designed to cut something but your traditional pliers don't have specific characteristics rendering them effective for applying torque they have characteristics that make them versatile they're used for holding why are there they can get in you know a lot of pliers and tools could be used to apply torque but that wouldn't make a traditional pair of pliers a wrench it's the specific characteristics that make it especially suited for and allow it to turn or twist or necessary nor required characteristics of the full complement of wrenches and in fact a number of those explicitly exclude tools that are commonly in commercially known as wrenches from the definition of wrench for example the requirement in the trade ports definition that a wrench similarly the requirement of having a singular handle would eliminate a number of branches including the cross because these these tools a mop and this pliers yes they are are but they were previously marketed by irwin's predecessor as  locking wrenches so the fact that the marketing has changed doesn't change the nature of the tool and it's not dispositive to what is commonly commercially known as a wrench so again the requirement of a singular handle which the exclude chain topic or sorry swedish pattern pipe branches which often have two handles and certain other wrenches that have more than one handle and the trade in using the singular handle looked at a definition  relied on also by irwin in webster's third international picture and it talks about ranges usually having a singular bar not being required to have a singular  ranches as a class of tools as we define them or specifically they have characteristics intended for grasping and applying torque and so the ability to use a tool to grasp and apply torque is in the definition of wrenches plyers being more versatile you would look at the uses to see if they nibble versatile tool for grasping in some cases cutting like cutting pliers stripping wires work like that the tool issue are wrenches under the appropriate definition because the locking mechanism renders them particularly suitable for grasping and applying for as early as chief engineer noted there are i guess one of the intended purposes of the model of model when it's locked is to apply maximum torque these are tools of last resort if you have a bolt or a faster that's been stripped and your other ranches can't strip it you can put one of these you know tighten one of these grasping and pull that or loose these tools the adjustable nature of them also as with an adjustable attritional adjustable wrench that doesn't have a locking mechanism would allow you to replace the whole set of wrenches you normally need a wrench for each i guess  lock but you know i'm not sure that that's in the records or clear from the record and so i don't have specific evidence i think it is i think it is in the record but i don't recall exactly where but you don't have to lock the vice grip in order to hold it when you loosen the bar and screw open the size of the head opening but when you were closing them i believe it still then lock just locked in a much more open position  locking and hold it fixed it wasn't locked and i could wrench that thing salutes are those players are moving how does the application locking it for convenience sake in a clamp style foundation make something iran's and not a clamp clamping function and in fact if you look at our use and marketing studies which are i believe let's see five fifty one i think tender let's go back to your sure your scenario you to define the term at issue players and locking players as it happens meets both the a s i me and the hand to god standard if you look at the s and it lists players it also in the hand tool standard list players and locking players come under both of those headings and the government has  you're going to go to the courts definition i'm not going to die on the hill the courts definition of french being correct your honor if i was going to define wrench i would say that was a base metal too with a single handle that one frame that is used to  use we don't have language to it within the terms of the statute that has some sort of in the shop like self tapping screw i believe it wasn't g r k or that in indicated they use neither wrenching or players indicate the use indicates an article together to enable a tool to grasp an object sounds like a player's the jaws may or may not lock together to hold the object while using the tool or judge or a knife leave what you're referring to is in the affidavit of mr lucas he had talked about that the tariff statute to be a class of article items it has to have specific language and there are plenty of court cases that have some help it has to say and similar articles there's nothing in the wrench provision that says in similar articles it's for things that's all we have and that provision so we are not within the scope of that provision either by the common meaning that's defined by the a s a me in the hand tool guide webster's dictionary which also the court relied on in making these definitions up and our the events so we have it a group of our class of players instead not wrenches and we have in similar articles cutting players regular players where they locker and you know one of the things that the victoria secret decision that the federal circuit use when talking about a just and generous classifications but players is that you know you have to use a common sense assessment of what articles are and it i common sensical that if we have the s m b and we have the hand tool guide and we have industry standards and that hand to a guide by the way is a consensus opinion of all the american manufacturers as to what these products aren't so so in it anything further counsel no i was going through my my list of notes your honor i don't believe i have anything further i know you're on no one ever loses points by not using the telephone thank you said mr glove my i'd like to make a couple of points first of all we're not contending that i guess let me back up in terms of opposing counsel statement that wrenches are not a class in the provision provision eighty two a four is an a o anomaly provision and as this court made clear and in other cases absent limitation or contrary legislative intent and nominee provision includes all forms of the named article even improved forms that's at six forty nine f there are at thirteen sixty four sixty five so we're merely stating that wrenches when it's used in heading eighty to a four is meant to include all forms of the article all forms are french and from g r i one we know that that means all tools that have a common a commercial definition as i stated on direct obviously