context for the invention and then get right to what we think are the board's errors here the real party of interest your vistaprint in the company that provides services so that people can print large posters and banners and business cards and things like the goal here was to provide an easy mechanism so that somebody could put together a big banner for their small business and have it come out right so the idea what to do with your web browser and two thousand load the top three component draw three programs or parts of it anyway to the browser allow the person to do all their work at their web browser the end have to buy a thousand dollars at top of the chain and then send the file back up for example to vistaprint servers we've looked at this technology a bit you're going to get us very quickly did this teaching a way reference measure and it says korea has a facility that has  you know what if you were moving to see through a series of different formats wouldn't that move the it seems to me it's not teaching the way when it doesn't address what our situation is so the answer is no and we did arrest this this is not something that the board handled and they just said that well in the event that what it is something that the solicitor brought up is this multiform that environment idea which i that and i'll tell you how so if you look at our reply brief we explained what you would do in that situation so you know my favorite example of this mall pipe for men vironment what i think they had in mind is you've got microsoft office and you've got this corral thing  and somebody sends you you know you're working with another law firm and they send you a word document what you ok and we explain what do you do you convert it when you open the document these are what you see is what you get programs and you want to know what it's going to look like on your desktop so when you look at it you see it in your format in the format that works with perot now is that just me making up no if you look at age seventeen to forty nine which if you just have the chorale document up read word and word perfect document that's your multiform environment and you get up to the top of the next page it says yeah it's very important to provide access to legacy documents so yes import and export filters will be provided in chorale office for java on the server level so when you open up the document you import and if you have word you can see how that works to when you click on something that isn't a word file it says you want to open this text file is a word file that's what the import and export is and that makes perfect sense because you want to see what the documents going to look like you don't wait until you print it now i'm having for a little trouble here because i need them rather than your argument as to what is being taught i need experts in declarations and people of skill in the art rather than attorney argument giving me guiding me through this technology and leading me to a conclusion that's obvious we're not so two points on that you need to have it can be declarations it can be experts but we have evidence right here in seventeen two four eight two four  nine of what parole with teaching and i think it's pretty plain i don't think that it is open to interpretation is that what that means convert it print time that's number one number two with the prime aphasia burden years on the board and on the office so to the extent we don't have explanation for this and we don't in the board opinion we have a statement up in the event that you wanted to convert you can use for me to convert and that's it and then there's no evidence to support that in fact there was no an event when you wanted to convert at least on what the board was considering we have the idea of this multiplatform an environment that the solicitor great stuff and this is our response to it so the board have some of found that requires conversion we say that's not supported by evidence they just threw that out there on page six of the appendix that's problem number one and then problem number two is the teaching away so we think they missed their prim part it teaches both translation when you need translation and no translation when you don't need translation so it doesn't have translation but if you put them together you go down the route affirming that says well we have this common format from have the corral file that is the doc file some form and it's one that you wouldn't convert because there is no multiple different types of files so ferman have two routes to go if you have a single format for  along if it's in the right format for him and leaves it alone if it's in the wrong format wrong but you know the one that is not the standard firman format then form and converts but in chorale there is only one form and third you wouldn't you wouldn't convert because you're already in that one format you don't need chorale for the conversion part you need chorale for the the part about uploading and direct everything and getting a pre press document is firm and you need for the translation are correct but you can't just take the translation of furhman to a reference that doesn't need translation isn't that the whole point of combining two references you wouldn't you need some reason to go get the second reference if you're the you know the filled sitting in a room with corral you're fat dumb and happy when it comes to printing you've got the solution that crowd came up with that's solve your printing problems you don't need conversion so you'd never go and reach out to ferment that's the whole krell isn't just for the corrals specific thing is right for this process of finding an editing file so it covers more than just you know the current product and the job of a surprise right so if you have some other thing that covered by that that does that is common and it's a web based the reason the crowd does this is it's it's a with the way so you want to know before you go to print what this document looks like that you don't want to wait to convert but didn't  mean the less restrictive pretty functions because it does it for some version when you open the document ok so they're not providing anything for chorale with you know they say it's greater flexibility but it doesn't provide anything  doesn't need that flexibility it converts the document when it opens the document and so it has no need for it there be no need to go get that ok they say well in the event that you needed to do that but there is no need to do that that's the problem there back lling to corral saying that there's a problem that isn't incorrect grell avoid that problem of print conversion because it does conversion when you open but they say well you in the event that you had to do print time conversion with chorale firman fixes it there's no problem to be fixed what if you're in not necessarily in corella but in another operating system the microsoft operating system reliance on the forever true you wouldn't have a problem because that's the whole point of a pow web browsers work is their platform independent ok so when you load a web page you don't get an apple web page you don't get a microsoft web page you don't get a  linux web page the whole point of having h t m l and web browsers is to be platform independent you see reference i'm in the corral document to your they say in their q and a what you guys are platform independent to some so in your example of microsoft would still be the same thing because you're inside the browser it's the corral document that's in the browser and it doesn't matter if you're on an apple a microsoft or anything else in essence you say the three reasons given to combine the motivations are insufficient for you saying it do we have anything in the record any expert who says oh no no one of ordinary skill in this art will never do that so i don't say they're insufficient i say they're not supported by any evidence ok they haven't pointed to the eventuality that in the event that to support that that event would occur and in fact we point to evidence in that those aren't in the record anywhere that they're battling for evidence it's not there and that it runs contrary to the statements in perella about not needing to do the print time conversion it's very important also the board never addressed that we brought just that passage out and highlighted it and then it one ninety one ninety nine in our rehearing we quoted that same passage again in our request for retiree we said you missed this passage you need to deal with the job environment there are lots of other different ways different software different platform different environments that one could use in a skilled ours and we know that so if a skilled artisan was seeking to implement a computerized pre press system in some other  environment or software program other than java translation may be necessary as shown by firman so while this specific implementation perella highlights the fact that no conversion is flexibility and increased capabilities of the of the translation in a network prinz environment and i think that you would want to go outside corral even though i mean if you're if you're going to implement the exact system of corral exactly the way to stop the reference i agree that you know you wouldn't have a need to do but if you want to change it in any way maybe do it in another software platform then there could be a reason to change it and one of skill in the art wouldn't be tied necessarily tied down to this specifics of corral he or she could look at corral and see it for what it's teaching in a broader sense for teaching the ability to you know have a sort of an online system where you download the offering program from a server to a client and then the user creates the document and send it back to the server for printing and that's the that's really the broader teaching of parabolas it's not limited to this specific job  i don't think that's the case first of all the the even part of the specific corralled white paper document that was at issue before the board in addition this argument that to that was never presented to them it was it was presented as a state is a different document if you look at  when it was before the board i agree i think the issues that that this prince out saying that a multi format environment would require translation and at the screening versus teaches translation at the prince or and that's what the claim of wires and so we have that specific teaching of translation of the prince or verb and the reason you do that is if you're running for example as foreman described you're running on a map hooked up  network that has a print server that turning dots and that example you would create your document on the map when that to do any translation but then when the document sent from the map to the perp to the dots print server the translation would be necessary for it to be compatible that's that's where you know translation comes in and that's where the translation service comes in what i did your argument about the culmination and the motivation of an ordinary person in  specific kind of citation to the record of our experts or anything like that but i agree the board's decision news was free from this point but if you look at the exact what the examiner said the examiner flushes up more for example the record and there is record evidence to support you would agree though that that corrals expressly said there was no need for translation everything yet it's got the import export servers that do the translation at the time that the program is no printed down right it's a bit that's only a specific example of if you're trying to open up for document in corral the translation right to happen i don't know so they said no and that's the only limited reference to translation in crown crown makes it clear that the whole point of crown there's no translation that's right i wouldn't say it's the whole point of the reference i think it's one feature of the reference i mean the whole the whole point of the reference is to provide  get a buyer situation so the end user is going to hit print and the documents going to be printed it's going to look like that what's on the screen whether or not you have i mean if you're if you're in the single format environment no translation will be necessary if you're in a multi format environment translation will be necessary for the specific reason to get the document to look like what it looks like on the screen so it's really just two different ways to get to the same people so make sure and understand what i think  process of having if you like it is on the screen printing and say well we can make it even more flexible and cover more systems if we combine it with for men's translation correct and the translation is for the specific purpose of ending up quickly i look back through the board's opinion i don't see three reasons and i think it's from the exam and that's from the examiner and they don't really know the of amateur weren't really a doctor those did not know there's nothing in the up in the show that the fo dominant one paragraph in the board's opinion that has the analysis and it just says in the event that out of everything else is in there every may be in the exam and that the court doesn't review the exam or the board views the board generally doctor requires the board to expert team focused on the pre press issue still think that's good it's not a good issue to take up on appeal to the front of reasonable interpretation but i can't tell you why a decision wasn't made i think you know it's clear from what the document says i haven't heard goes to the standard review point to i haven't heard any argument meaning a disagreement over what is being taught in these references and that's why this is legal review the statement is clearly a teach in a way there's not a  dispute in this case about technically what's the on it it's a dispute about legally what is the implication of that and so i believe i wasn't part of the team at the time but i think what they looked at is that we have simply restatements and  they make those arguments off the evidence or e record off of the paper record instead of adding a declaration but i think the example of the map dots example is classic hindsight and the idea of well we go get this extra thing to provide even more flexibility the flexibility isn't needed and in fact about following the court back to two four nine one seven two four nine of the record and this is the platform independent statement in parole the questions as you say chorale office for java is platform independent but it isn't working on my platform what's up and then they go on to say that this the number of supported operating systems and browsers increases almost daily and includes sun solaris a i x which is an i b m operating system o s two just that now two windows ninety five windows n t and man macintosh ok so the sun system itself says we're working on all of those operating systems and the reason the way that they do that is through the filters and they don't need translation that's what this reference says we are in a multimedia not multi format in a multi operating system environment in a heterogeneous environment and what we're doing is a boiling print time