now the many complaint alleges that this inventor concept improves vehicle technology in three ways st by helping to reduce driver distraction that's a paragraph twenty one dollars of them in the complaint also by permitting access to operate the singles normally disabled test assume for me with me for a minute that an assertion about an improved property safety handle ability or something doesn't itself count what you need and this is something this is the distinction i'm trying to explore is an assertion about a new physical arrangement or physical set of steps it seems to me that maybe everything said in the declaration and the amended complaint is all about here's why this stuff is beneficial position camera devices confute attached to a custom processor and all that configured to capture gesture controls physical gestures and driver and passenger and translate those to control of the physical vehicle  what if the claims that this vehicle operating system in which the car is able to see gestures made hand gestures by being made by the driver something like this are like this and then the car then interprets those gestures and then acts accordingly turn on the ac turn off the heat turn the radio station on to n p r with that be an abstract idea or would that be a claim with an inventive concept because now you've come up with this insight of making cars drive more safely with the driver because the driver can just use little hand gestures rather than trying to signals where the gestures are capture simultaneously and so this is where the you've got a processor in your claim that is able to interpret that hand gestures that's right and then the being able to receive simultaneous gestures from both the passenger and the driver is of the most people that camera devices must be position in such a way that they can detect and receive those positions so i wish i mean you could if you're going to do some kind of processing video received signal the camera has to point to where the hands are the hands and also to oh it will get big actually these claims aren't even limited have right this is essentially a video version of voice recognition of gestures or anything else by a computer with a processor that recognizes some of them and translate them translates into action i think soon that that's not at that level so what's what why is this anything more than we do that in a car well you know this is something that has not well it isn't a car isn't vehicle as addressing problems are specific to vehicle technology you know this is driver distraction is not just a generic problem out there in the world this is a problem specific to be able to acknowledge and what's described in the specification on this record is that i inventing these camera devices in such a way to capture simultaneous gestures from driver and passenger and then translate those to vehicle control that is novel that's not something that's been seen before it's not capable your cars had before so there is an improvement wholly new way of recognizing and processing certain kinds of signals to do something then you're taking the end of processing and video and and inputs that come from a video transmission video just meaning that some camera or something is seeing something you're taking all of that as background prior art because that's not claimed as an advance you're just saying this would it would be a good idea to use this in a car where you're saying that it will goes beyond seem to be a good idea to use the car you know the saying is that there's a problem there's a technological problem in terms of driver distraction and how are we going to solve that problem and yes it's using camera devices camera devices are not new but inventing camera going to including including processors behind them that do so in some interesting you lose the heart of what the claim is directed to and the claims of the three hundred and seventy three are directed to the system that's in this current some proven technology not just the abstract idea of collecting information analyzing and displaying in several ways courts presidents operating system priest want to play is is this technology that allows you to move images around on digital displays and the shared specifications starts on this issue but acknowledging that that something that pree four through twenty five is a shared specification developments in liquid crystal display technology have made free form display on a dashboard a reality so that's what we're talking about you are talking about a preexisting technology freeform display similar to a picture in picture function on your television set report push a button and a new program pops up in the corner of your screen so you're watching two images at the same time which another button and it moves back you're moving this preexisting technology into a car all the patents make clear that only generic components are used there's no new screen technology as i believe your honour's have recognized that's acknowledged to column three lines one through five dashboard screen man clued any display technology that's up such as an l c d crystal l c d or l e d the specification all makes also makes clear there's no new processing technology there are no specific instructions regarding how you program these various components to move information around on a screen or switch back and forth a column six last me through to twenty four excuse me twenty four thr twenty nine the configuration is why don't you just shoot receive user signals and perform any other operations the signals can go in the excuse me the screen displays can move in any direction they can be separated or clustered on top of one another they can be switched back and forth after any pre determined time period and any signal can be used that's all found in column five it can i ask  display where the camera captures some gesture there's a processor that like you know o c r tickle character recognition or gesture recognition i don't doesn't look up and says this the set of pixels or something on that the input means the following and now ready i think that correlates with an instruction and it's shown on that order i don't believe there's any dispute that that's not considered new technology i do know that under has not made any allegations in the original or a minute complaint that the use of gesture control or camera devices placed in an automobile by guess is that i believe that's the that's the free form display where you're just moving information back and forth you don't have to use hand gestures you can push the a button on the screen you can rotate a dial it's any type of signal can be used and so as far as i can tell their argument is that it's they've improved vehicle technology because they've him put this preexisting technology into a car which enables a driver for example to switch the navigation screen to move in front of the passenger so the passenger can then dictate how the navigation works without distracting the driver and then improve safety but it i believe that misses the point i believe your honor was on to this with with earlier questions that in fact to be the st question you asked which is are we talking about an improvement to the car or are we talking about an actual improvement to the technology that's being put into the car and here arguably putting this type of a system into a car can perform and make it safer but there's no legitimate argument that the technology used to make it safer has been improved and i think that's where you get into these cases the talk about the field of use taking preexisting computer technology and putting it into a new field of use does not create does not make it an abstract idea not abstract or make it unconventional i think that's the real distinction that you see in these cases they're  know numbers of cases that this court has or opinions this court has issued to make it clear that you can't take this preexisting technology computer technology and put it into a new field of user environment and claim there's an improvement in that environment it would be akin to dropping life i technology into a car which we know is happen course that makes cars more user friendly but the wife by technology itself would have to be improving or be in order to get a patent on that and and we that involves similar technologies and i think here we have some really similar decisions with respect to the three to nine and the seventy four patents the interval licensing decision is very similar in that the are the the patents involve the use of a and attention manager to control the display of two sets of information on a display screen such that they would not overlap and they would not be distracting from one another like a ticker at the bottom of the screen there was no new technology involved in doing that the court found that that essentially amounted to collecting analyzing and displaying two different information is that there was no claim about no new claim technology i think that's what we have here without disclosing a subpoena a specific improvement to the way computers or other technologies operate and that's the language i think that gets back to what is being improved the technologies that perform these functions are not being improved in this particular and these patents moving to alice stepped to the interval licensing court said you're basically doing this with generic component components you're not teaching us how to do it which is what we have here as well there are no there are new details in the specification or claims that teach somebody how to process how to configure the processor to move information back and forth on the screen or how to switch it back after a pre determined amount be new i think on these pads it's a very difficult it's very difficult to get them to patentable subject matter but i i suppose they could have come up with a unique unique way to reconfigure and move information parent i would say more detailed teachings on how you configure the system as a whole to perform these functions as it stands it just does make a signal the information moves to another panel and then it move at that point years your skill programmer probably could do that and the patents talk about that but then you're getting into a kind of preempting a field because there are no confines within the patent as to what steps you have to follow to perform this process is just do it and so you get you you're getting into a very broad subject matter that i think would cause preemption concerns in this particular field you know that's not way of capturing gestures or of trance meeting or transferring gestures or transforming gestures into signals so the operating system can perform operating system can perform signals  they don't take they don't teach any new ways of turning gestures into signals war resulting conflicts between gestures so for example there there are no teachings regarding the specific placement of cameras where cameras need to be placed to accurately capture gestures and understand it's a gesture coming from a driver as opposed to a passenger the claims don't say anything about specific locations of the camera devices claim one says just its camera devices as it have any any placement criteria the specification makes it clear that any type of camera devices can be used located at any location that's in column four lines fifty three thr fifty nine and they also make it clear that any type of gesture recognition techniques can be used on preexisting column five lines five thousand eight hundred and forty one through forty four various just a recognition techniques based on capture images and it column seven goes on to say this man include various types of pattern anatomical and or motion recognition technique is there something in this that that to saying something false and there are no i would like to know what where i almost misspoke i don't believe you have there are no allegations of any new gesture recognition techniques or camera devices used to capture your gestures for example at night when it when it might be dark but it doesn't don't reinforce their position that there is an inventive concept in the overall compilation of steps and knowledge in the individual and therefore we don't need well the details of the individual steps as i was inquiring well i don't think it does based on this court's precedents because you know in an interval licensing and electric power which i think is actually closer on this particular the findings were that when you're performing steps that can be formed with generic computer components you have to you don't have an inventive concept unless you teach the how how you achieve the new the new concept the supposedly inventive and here we don't have those details in the specification or the claims and so i think it would be it's contrary to the holdings in interval licensing and  electric power to find it that would be that could be inventive and this particular case i'm looking for a particular quote that i found was relevant the electric power case the advance the assorted claims purport to make is a process of gathering and analyzing information of a specified content then displaying the results and not on any particular assertively and then of technology for performing those functions that and fifty three and i think that's that's exactly what we have here and i see that i am down to five seconds if the court has no further questions i duplicate depending on user signals that's changed our cars operate conventional cars don't do that conventional car so they don't do that change how vehicles operate that's a change in their capabilities and or singe in other cases that mechanism for accomplishing this a given x isn't to specially pollution cameras a system involving the two specially position cameras the custom processors configured to translate gestures from driver and passenger not just one simultaneous gesture from driver pat scribes how the gesture how the the processor determines whether or not the passenger or the driver is the one that's making the particular gesture it does that by determining whether or not the gesture observes and the rest of the passenger image continuous in other words whether to go from the hand to the head or hand to the restaurant had some other body indicator and that's was clean a six and seven a different way of capturing those gestures and there is no evidence in the record that that was well known routine or conventional so to say that all of this is convictions conventional gesture capture technology that goes beyond the record we had before  and finally to your last point you know and we're not claiming that we invented cameras are not claiming that we invented processors but we are complaining the system entirely the system that we're talking about in this course pre  that says you have a different standard talking about eligibility for is invalid of the under section one hundred and twelve dollars and these claims provide that level of specificity provide at least a level of specificity yes the how as we see in the phallus case we see individual memory providing enough power simply not correct under fellas under visual memory those are the same level of specificity in these courts like in those in these claims like in those cases should be held