converting the input power voltage to the output power boat for determining an off state of the circuitry in this case there's an issue as to whether the patent and trademark office the quote did not conclude that quote converting close quote is limited to the c slash p c conversions close quote while i did i don't i don't disagree with that i think that they did not say it was limited ac d c converting they came up with something inbetween your honor i don't think i undressed in my brief because i don't think it's an issue here i think everybody agrees that the p t had came up with a claim construction that included something more than ac d c converting and that was the problem in this case because they plan on argued one construction the patent examiner and the requester followed a broader construction and the our interpretation is important rule because there's the supreme court reminded us recently the purpose it does increase the possibility that the samurai will find the claim too broad and deny it and  provides support for that definition and one of the problems i have with what the board did is that they relied on the specification of the six for eight and that's a later followed continuation impart application and they took new matter from that specification and relied on it in reaching an interpretation of this patent including information that was not in there and even the board at knowledge that the honor i don't believe that the board's attempt to distinguish between our terrain and converting was a valid distinction in my view and i believe i can demonstrate on the record in this case converting includes filtering the board found otherwise but in my view converting includes filtering and in this case unit and the question is is this converting the voltage from the power input into the power output now your honor if you would look in the record a ota haru reference specifically at four nine seven one which is figure two of that reference this shows  including the rectification which is number eleven and the smoothing function provided by the pastor number twelve west filter so i would respectfully submit about we're talking about the broadest reasonable claim construction converging and therefore found that there are more than you want that is correct it's because this is some evidence to support the notion that i can do that too if you look at the original prosecution in the original prosecution the patent owner effectively defining defining what converting net in the original prosecution which is in the record at five eight three four the patent owner distinguish her reference to genes and in doing so the patent lawyer emphasise that the chinks reference quote which when closed simply a while it's the same input voltage to pass through i e without any conversion as output voltage and that said five eight voltage it's converted evolved and this is reinforced by their own brief where they argued in their brief that when you use the symbol  broadly is not inconsistent in fact it's consistent with this argument that they made no i agree with you this argument doesn't go so far as to define it but it does provide very strong evidence that the construction of the  to amend the claims to provide certainty in this case if the patent owner wants to take the position that circuitry for converting means something other than making some change or to the for all star i'm sorry for superior to overcome the first is a fact finding the second and third are the legal issues of plain construction let me start with the fact finding the three independent claims are shown on pages four and five of our principle brief each one has a portable rechargeable device as a preamble to the plan board found that this means the device must have a d c input is the record of pages forty nine fifty four fifty six and sixty two and that the gang reference was to an ac device and this is in the records at twenty three forty nine sixty two therefore the board properly concluded and disappearing has not be but the fact that the yang document is for a different kind of device entirely and does not meet the language of the claim that's a fact find not the broadest possible but the broadest reasonable and in light of the specification which talks about altering there is something that is not to be included in converting there for converting does not mean every possible change to a signal if we didn't have that there's those discussions of altering in the specification would converting normally in this field include the noise reduction that for example over a general dictionary and that the technical dictionary to jackson referred to in the record of page fourteen supports the board's conclusion of play meaning the board also said that tried to say it is broader he was able to give no examples of this is in the record of seventeen at the board expressed they rejected the attorney argument in the record to page eighteen because it was not supported by any citation to the record so how broad is converting i don't know but in the context of this document it cannot be every possible change to voltage otherwise as the board said every circuit would then be a conversion no power there has been absolutely no response to that issue and the third converting to just address but i do want to mention one thing to the port we have dropped by agreement across appeal we're aware of them i want to tell you what claims to still remain in the case because some of the claims were rejected under a new grant of rejection and they're no longer in the case so this is what still in the case in american order four and five eleven to twenty seven thirty three to thirty seven and i would tell you that four and five do depend for independent claim one which is why i referenced it in my remarks a few moments ago and that's on page one the chart is on page forty five of our principle brief so history should factor into the broadest reasonable interpretation analysis when they are saying rebuttal you just heard counsel get up here and say how broad is converting i don't know that's what the broadest re