construction argument that speaks to the creation of a national question on that database requires a special normalization process and requires a national personal foundry database to be used in searching for personal it expressively recognize boundary solutions candid admission that while there may be a difference in terminology a look up table serves the same purpose as an index why shouldn't we treat likewise treat that as a mission by your client regarding lookup table if you read a the argument in contacts i was the attorney that did the argument that the the statement about serving the same purpose is that it was it is one of the purposes that a lookup table can be used for in this case in this patent it is used for an additional purposes including the the the arrangement of the entire database search protocol to engage in a two stage search where where in the lookup table is a jurisdictional look up table to find a you do it on on your response you can just point and in terms of that two state search as represented in the claims themselves you see that they are and parcels of surrounding it so that's why we say we say that there there's no implementation steps of how that second stage occurs but it is pla each county has already established through its tax assessor office a map that includes a p i and set locate particular parcels by using the i mean i want you to i don't wan you can tell me where we where that is in the record ok so so that are easy as to the limitations that we're discussing as missing in harder and decisions over the course of less than two pages that spanned from page seventeen and nineteen and decisions that appendix seventeen to nineteen which respect to the nine four six pat art renders the patent obvious and according to their randi and other cases the board is required to lay out specifically its reasoning  obviousness is is sort of like freaking the free speech beach concept of you know it when you see it there so it's very difficult to to focus in on  exactly what what leads one to believe that a invention is obvious well i mean so i guess in principle i understand your point but it seems to me needing carefully the boys opinion i mean they take each argument specifically on the pending seventeen and eighteen and two approaches they take each of your arguments and they respond to it quite specifically presumably not necessarily to your satisfaction but it seems to me reading the opinion that they do identify the arguments you make do cite the references and do pride of splaying based on the references and what they understand to have been your concessions during the oral argument that as we present the argument that the grid in tax which is the closest index in the long leonhard or that comes to the two stage search we present the argument that it actually only pre tra different kinds of looking up tables and explained why it is that one ordinary scale mean are oid i understand that there could be a look up table based on the teachings in the two references what what i believe that reciting look at the table and then if you look at that quote it's conclusory statements about why that is true with a single citation to good child declaration forty four if you look paragraph forty four of good trials declaration which is the only only paragraph in the whole declaration in which he says he addresses the reciting jurisdiction look up table you will see and that's at appendix four seventeen that he doesn't provide any reason why one skilled in the art with automatically think of look up table what about where reference the index in automatically think that here's how you structure this parcel database the jurisdictional look up table that first finds a jurisdiction and then find the already in all of the counties databases those two pieces of information linked together give you any unique identifier for every parcel across the nation so you can use that to create a searching mechanism to find like that parcels that there is nothing in longly or harder that comes close to suggesting that kind of  invention involves no more than the application of standard database management techniques to particular datasets because the method organizes the claim method organize it is the data by jurisdiction the claims simply affix the label jurisdictional the standard tools like indexed look up tables databases identifiers and segmented databases that does not satisfy recounted all of those arguments and it stepped through not only the references hard and long legs but it pointed to the specific parts of the titian which in turn elucidated the parts of the declaration that address these issues identifier is used to search another table to identify records with matching identifiers harder disclosures searching indexing rather to speed up searches the databases longly discloses not only in the axing generally but specifically that usage search with a look up table and that's the discussion of the grid index and what a great index i boxes and they have a lookup table the atlas would have a look up table where you could identify the jurisdiction that you wanted to travel to so if you want to go to alexandria it will say page for cell be three and therefore it speeds up the object the grid location of the object is listed in the index is recorded in the list it's an index and this is a lookup table because it has columns and rows it would be effectively the object look up table is a form of index and i don't think there could be any other any other dispute about that now of a look up table as a broader term dr goodchild testified that for example you could only all fashion times tables you avoid the the lookup table is an index and so inductively job is decoration talks about how the you know based on these references that the this is the use of indexing techniques to provide look up harder and it's also important to understand the key and contested points that dr goods are testified to about the background knowledge of one skilled in the art and there are three i think that are important first the g i s commonly employ standard relational database software all of which have indexing commands second it was well known in the art to partition a database into separate tables by jurisdictional levels and for indexes to be used to search other locations in the day so that's why we say all that we have here is the application of the standard technique to a particular type of data and they're just saying well this type of data   to have a pattern that's considered obvious over prior art so there's not really no question here the board did not resort to common sense as in a ready supply missing claim limitation it only looked to common sense missing limitation or a situation where there's a combination that's being supplied motivation to my argument is not at all about motivation to mine here we all  textbook describes in general a lot of different indexes are trees climb trees that everybody understands it's not relevant to this case that the best index that they rely on the great index and if you read the two pages of the orders decision they have a quote from long lee of one line about this great index which we think actually proves that it's one stage search but there's no analysis there of why the great index of long way is is not applicable to this patent there and there is no sense that you can use that grid index about it is to identify the jurisdiction of a county or city it's really highly unusual that those would be in the nature of a rectangle if they're not in the nature of rectangle pretty index doesn't work the idea of great indexing is to pull place smash to go hide out the map and there's a whole discussion of that what what resolution you apply to that m but it's going up and down and objects are located they have an identifier you don't need to use the grid that identify them and so what it says is you not fa two latitude and then you pull out for further analysis object geometry its relation to other objects you know a whole bunch of information but that's