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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`WHATSAPP INC.,
`Petitioner,
`
`v.
`
`TRIPLAY, INC.,
`Patent Owner.
`____________
`
`Cases IPR2016-00717 and IPR2016-00718
`Patent 8,874,677 B2
`____________
`
`Record of Oral Hearing
`Held: March 5, 2019
`____________
`
`
`
`
`Before JOSIAH C. COCKS, BRIAN J. MCNAMARA, and
`FRANCES L. IPPOLITO, Administrative Patent Judges.
`
`
`
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`IPR2016-00717 and IPR2016-00718
`Patent 8,874,677 B2
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`
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`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`YUAN LIANG, ESQUIRE
`HEIDI KEEFE, ESQUIRE
`Cooley LLP
`3175 Hanover Street
`Palo Alto, CA 94304-1130
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`DOUGLAS WEIDER, ESQUIRE
`Greenberg Traurig LLP
`500 Campus Drive
`Suite 400
`Florham Park NJ 07932
`
`
`
`
`The above-entitled matter came on for hearing on Tuesday, March 5,
`
`2019, commencing at 1:00 p.m., at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`P R O C E E D I N G S
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`JUDGE COCKS: Please be seated. All right good afternoon. Judge
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`Ippolito is going to be starting us off today so please direct your attention to
`her. I think she will be showing up there. Judge Ippolito, can you hear us
`today?
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`JUDGE IPPOLITO: I can hear you. I don’t see myself -- oh, there it
`is. Okay. Good afternoon. This is a supplemental consolidated oral hearing
`in the cases of IPR 2016-00717 and IPR 2016-00718. These proceedings
`both involve U.S. patent number 8,874,677.
`The final written decisions in both of these proceedings were entered
`on August 27, 2017 after oral argument was held on June 12, 2017. On
`October -- November 14, 2018 the Federal Circuit issued its decision
`vacating and remanding these proceedings to the Board. This is a post-
`remand hearing to address remaining issues in both matters.
`I’m Judge Ippolito and with us today are Judges Cocks and
`McNamara. Some of us are participating remotely today so please
`remember to speak from the podium so that all of us can hear you and
`remember to identify by slide number any demonstratives you’re referring
`to.
`
`And per our order, each side will have 30 minutes of total presentation
`time. Petitioner will begin today and present its case regarding the
`remaining issues in these cases and patent owner will have an opportunity to
`respond. Petitioner may reserve rebuttal time as well.
`Could I have beginning with petitioner the parties introduce
`themselves?
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`MS. KEEFE: Thank you. Good afternoon, Your Honor. Heidi Keefe
`
`on behalf of petitioner WhatsApp. With me in the courtroom is my co-
`counsel Yuan Liang and in the audience is our client, Nikki Vo. Thank you.
`
`JUDGE IPPOLITO: Thank you. Patent owner?
`
`MR. WEIDER: Doug Weider, Greenberg Traurig on behalf of
`Triplay and with me at counsel table is Steve Pedersen counsel at Triplay.
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`JUDGE IPPOLITO: Thank you. Are we ready to begin? Petitioner?
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`MS. KEEFE: Yes, Your Honor.
`
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`JUDGE IPPOLITO: Proceed.
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`MS. KEEFE: Thank you, Your Honor.
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`JUDGE COCKS: Counsel, before you start, are you going to reserve
`any rebuttal time?
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`MS. KEEFE: Thank you for reminding me, Your Honor. Yes, I
`would like to reserve 15 minutes.
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`JUDGE COCKS: I only ask so I can put something into my device.
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`MS. KEEFE: I appreciate it, Your Honor. Obviously what is most
`important is answering your questions so if I go over there, I have no
`problem because I want to make sure that I'm answering what matters to
`you.
`
`So we stand before you today after the Federal Circuit’s decision on a
`single simple issue which is whether or not there was a motivation to
`combine Coulombe, Bellordre and Friedman in order to find the clickable
`icon element of the claims at issue in this case.
`And I have on Slide 2 in front of Your Honors right now just Claim 1
`showing the language clickable icon which appears in the limitation sub A.
`The same as in Claim 6 as well and that's on Slide 3.
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`On Slide 4, I wanted to start with observations made by the Federal
`Circuit. The Federal Circuit held that quote there is no dispute that
`Coulombe discloses a majority of the claim limitations with the exception of
`two limitations. Adaptation of video objects, a limitation petitioners find in
`Bellordre and clickable icons, a limitation petitioners find in Friedman.
`The Federal Circuit went on to note that together, Coulombe,
`Bellordre and Friedman disclose all of the limitations of the 677 patent. A
`fact, which was conceded by Triplay at the first oral hearing before this
`Board. And that’s in the transcript of the hearing at page 65 column, sorry,
`page 65 lines 17 through page 66 line 8. And this is on Slide 4.
`And I raise that to make sure that we reemphasize the only thing that
`we are addressing here is whether or not there is a motivation to combine the
`three references because there is no dispute that the combination of all three
`references includes all of the elements of the claims at issue.
`And as explained by the Federal Circuit, they vacated the Board’s
`non-obviousness decision and remanded for further consideration of the
`motivation to combine the clickable icons of Freidman with Coulombe and
`Bellordre, citing to the Federal Circuit opinion.
`As explained by the Board, the Federal Circuit remanded for further
`consideration the motivation to combine the clickable icons of Freidman
`with Coulombe and Bellordre.
`And I know I have said it about three times now, but it bears repeating
`that it is a combination of all three references because I anticipate that Patent
`Owner will argue that there is a problem with the combination of simply
`Coulombe with Friedman and arguing that there is not a logical link between
`Coulombe and Friedman. But that’s the incorrect question. Because the
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`issue is always the combination of all three items.
`And in fact, I would like for one second, and I’m sorry, I didn’t ask
`for the ELMO but I just wanted to note that the Federal Circuit noted in its
`order remanding that specifically the Board needed to consider the testimony
`of Mr. Klausner that the advantage of Friedman's clickable thumbnail
`graphic is self-explanatory. It makes possible to view a video object by
`clicking on an icon.
`Federal Circuit then went on to quote the other reasons that Mr.
`Klausner had given. Among them the fact that the advantage would have
`been to allow a recipient to make a more informed decision of whether he or
`she wants to download the video from the message server thereby
`conserving device and network resources end quote, citing to Mr. Klausner's
`declaration at paragraph 48. That's his reply declaration.
`So we know from the combination at issue here, Coulombe was a
`system that transcoded information. It would take something like a photo in
`a sent message, apply it to a server that would -- the messaging system
`would then recognize whatever that picture was and then transcode that
`picture so that it would appear the right way on the receiving device.
`We then needed to look to Bellordre to find a video instead of a
`simple photo. Bellordre discloses use of attachment objects and the objects
`can include video objects. A fact that the Federal Circuit also found.
`Bellordre also discloses very plainly and clearly the generation of a
`representative image based on the video that was in that attachment. And
`this is seen in sequence number 27.
`And I have a figure on Slide 6 up in front that shows Bellordre's
`Figure 4 shows the representative image of what would be sent to the
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`recipient after the conversion process has already happened. So the video
`object is sent in, it is stripped out, recognized to be a video object transcoded
`and then sent along with number 27 which is the sequence that is essentially
`a representation of what is in that video.
`And the specification in Bellordre talks specifically about calling out
`maybe the first image of the video or some other important image so that
`people know what the video that’s being attached is all about.
`The message also include box 28 which is the description of that
`video object and 29 which is listed in the specification as the URL for that
`video that transformed video object.
`I have the quotes here in paragraph 63 talks about the fact that there
`will be a sequence in the case of a video object. It may be a representative
`images and this is on Slide 7, Judge Ippolito, I apologize. And in paragraph
`102, indicating that the sequence 27 is inserted into this message and that
`sits at sequence 27.
`Therefore, we know that Bellordre already discloses something akin
`to a graphical icon, this representative image of a video that can be inserted
`into an adapted message. And that quote comes directly from the ‘717
`petition at pages 27 through 28 and the ‘718 at 33 through 34.
`Petitioner admitted however, that Bellordre did not disclose the
`representative claim image itself being clickable as required by the claim.
`But that's where Friedman comes in. And that quote comes directly from the
`reply paper 26 at page 22.
`Moving on to Slide 9, Friedman is now brought in to the combination
`to disclose a thumbnail graphic representation that is clickable. Friedman is
`a messaging system that deals with how do I deal with the attachment to the
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`message? What do I do with that attachment to make it easier for someone
`to read? Easier for someone to view what is going on.
`Friedman discloses that a thumbnail graphic like 525 is for the
`Riddick movie, the files of Riddick movie and it has a first identifier that
`comprises the thumbnail graphic representation of that video.
`The Specification goes on to describe what a user can do with that
`icon if they wish to access it, they can double click, among other things to
`carry out what is underneath that thumbnail graphic.
`And we also know specifically from Friedman that this can happen
`either at the client device, server device or a combination thereof.
`One other argument that I think was made by Patent Owner is that for
`some reason he thinks email is the only thing disclosed in Friedman but
`that’s absolutely not true.
`The very first section of Friedman I think in column 1 as well as
`column 2 specifically details that IM's are included in the messages and
`that's at Friedman column 1, lines 15 through 20. And Friedman column 2
`lines 30 through 36. Which specifically define an electronic message to
`include the instant messaging. Instant messaging being that which was the
`subject of Coulombe.
`Motivation to combine Friedman’s clickable icons with Coulombe
`and Bellordre is because you would want the clickable icon in order to allow
`for straightforward access to the video that’s attached to the message. And
`for that quote as you see at the bottom of Slide 10, we are citing to
`Klausner's opening in paragraph 74.
`
`JUDGE COCKS: So that’s the motivation? That’s what we should
`look at? Straightforward access to a video attached to a message? Because
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`your first paragraph, I'll just make this point, it doesn’t really have any type
`of motivation. It is the conclusion you want us to draw obviousness but it’s
`not itself a reason.
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`MS. KEEFE: Your Honor --
`
`JUDGE COCKS: Wouldn’t you agree?
`
`MS. KEEFE: -- is absolutely right. Your Honor is right. The second,
`the motivation is to make it easier for someone to see. And Friedman itself
`actually talks very specifically about the fact that using the system of
`freedom -- Friedman is in order to make it easier for a user to find the
`material that they're looking to.
`In fact, Freidman specifically says and this is in column 2 line 31
`through 35, that using Friedman results in a more straightforward and less
`arcane management structure to access the information in those attachments.
`So Friedman itself provides a portion of the motivation.
`Mr. Klausner said that was one of the reasons as well. Mr. Klausner
`also went on in his reply declaration and I want to jump forward to that, for
`another motivation and this is on Slide 13. To indicate that not only would it
`be easier to view it using a clickable icon, but in fact, it would also a user to
`make a more informed decision of whether he or she wants to download the
`video from the messaging server, thereby conserving device and network
`resources.
`Because if you see a little thumbnail of what this is, you might know
`that you don’t need to click on it because oh, I have already seen that one, I
`don’t need to see anything else. Whereas when you see a long text string,
`you might feel the need to click to understand what it actually is.
`Moreover, in that same reply declaration, attached to paragraph 47,
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`Mr. Klausner attached to his declaration and referred to Exhibit 1136 which
`is a chapter from a book called Master Visually, the Complete Visual
`Reference. And on the very first page of chapter 11, we have the notation
`not remarkable that quote images make better more intuitive hyperlinks than
`texts.
`So again, the notion that it is easier, something that is more visual,
`more easy to use, less arcane, more straightforward and in fact also helps to
`conserve network bandwidth and device bandwidth because you don’t have
`people necessarily having to click on everything.
`And so all of those things are motivations to combine. In fact, patent
`owners own expert admits that Friedman describes -- this is on Slide 12.
`That Friedman describes using clickable icons as a way to give
`unsophisticated users easier access to the received attachments. And that’s
`in Dr. Surati's Exhibit 2017 at paragraph 100. And is referred to in patent
`owners response, paper 23 23 at page 58.
`And so this is an undisputed motivation to combine. The fact that
`using this clickable icon would enable one to easier access the underlying
`information.
`
`JUDGE COCKS: Counsel, could you give me that cite again that you
`just made to the?
`
`MS. KEEFE: Absolutely, Your Honor. It’s on Slide 12 and it’s to
`Patent Owner’s expert Surati's declaration, Exhibit 2107 at paragraph 100
`and I believe it’s actually the second sentence in that paragraph, You Honor.
`I’ll just get that out for you.
`Yes, Your Honor, it’s the second sentence of the paragraph. The
`paragraph starts the generic statements made for this limitation provide no
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`valid motivation to combine Bellordre's add extraction module with
`Friedman clickable icon and then combine both into the Coulombe
`adaptation engine 20.
`Next sentence. Friedman describes using clickable icons as a way to
`give unsophisticated users easier access to the received attachments. So the
`motivation to combine is actually agreed to by Petitioner’s own expert.
`Instead, Your Honor, what we I think are a series of arguments that
`the references are not combinable because either they try to combine
`Coulombe with Friedman alone, ignoring the fact that Bellordre is a proper
`part of the three item combination, and in so doing they say that you
`wouldn’t combine Coulombe with Friedman because Friedman is about
`messages, Coulombe is about streaming, therefore you would never combine
`them and you wouldn’t even get to the next step.
`But that negates the fact that its Coulombe plus Bellordre which gets
`us to the idea that we have an attachment and then once you have the
`attachment with a representative icon or image, you can then use Friedman
`to say all we want to do is click on that icon in order to make this the easiest
`way to gain access to the attachment.
`The other arguments that seem to be coming from Patent Owner are
`that when you click on any icon from Friedman, you are not taken to an
`adapted message but that ignores the fact that it’s a combination. It’s not
`Freidman itself.
`Friedman itself does take you to the original image that was sent in
`but when you combine Freidman with Bellordre and you use sequence 27,
`the icon and make that clickable, you are taken straight to the adapted
`version. Nothing else.
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`And then last but not least, their argument seems to be that there is
`simply no motivation listed in any of the history of this case but very clearly
`as I have already pointed out, Mr. Klausner started out by saying this was
`the most straightforward way, easiest access, most straightforward.
`Mirroring the language of Friedman which says I want a more
`straightforward way, less arcane.
`And then in the reply brief attaching that icons are easier and more
`useful than texts for hyperlinks as well as the fact that you can have network
`superiority. Thank you, Your Honors.
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`JUDGE COCKS: Thank you. Mr. Weider, whenever you are ready.
`
`MR. WEIDER: Yes.
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`JUDGE COCKS: Thank you.
`
`MR. WEIDER: One second, let us try and get this. Okay. Good
`afternoon, Your Honor. And again, I appreciate the last minute notice and
`the permission to proceed without lead counsel present.
`WhatsApp makes much of the fact here that all the limitations can be
`found somewhere within the three different references. I think you have
`even got a sense as you were going that the level of different gymnastics that
`they go through to try to put this whole invention together.
`And what they really gloss over is the fact that the primary reference
`when you actually dig down and look at these clickable icon limitations or
`the various aspects of the messaging conversion, there are a number of
`different limitations that aren’t present in Coulombe.
`And we have a slide here that goes through, this is Slide 2, that
`references the three disputed limitations that remain. This is using -- I
`emphasize this enough, this is using a clickable icon as part of a messaging
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`conversion.
`And I would maybe it's probably worth pointing out here if you look
`at the Petitioner’s slides, I think there is an important slide here where we
`talk about the motivation. In particular if you turn to I don’t know if you
`have, do you have handy the Petitioner’s slides?
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`JUDGE COCKS: We have an electronic copy.
`
`MR. WEIDER: Okay. In Slide 13 which Ms. Keefe referenced
`which talked about the advantages of allowing a message recipient to make a
`more informed decision of whether he or she wants to download the video or
`not, we don’t disagree that that is an important advantage of the claimed
`invention here.
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`But that’s just a leap of conclusive to go from Friedman to those
`benefits. Those benefits are associated with using an icon as part of a
`messaging conversion and I’m going to go through this in a little more
`detail.
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`JUDGE COCKS: Actually, Counsel, before you do, I have a
`question.
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`MR. WEIDER: Sure.
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`JUDGE COCKS: You have on the screen here, you are talking about
`the three disputed limitations of Claim 6.
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`MR. WEIDER: Yes, sir.
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`JUDGE COCKS: But did the Federal Circuit already make a finding
`when it comes to the limitations of the claims? What are we to take from
`just the quote together the three references disclose all the limitations in the
`‘677 patent. Is there any wiggle room here?
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`MR. WEIDER: I believe there is for sure. I, look. The Federal
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`Circuit, I was at the argument. There was no discussion of any substance at
`all regarding the nature of the clickable icons present.
`The argument was made, we made it, that there were multiple
`arguments that had not been addressed and if the Federal Circuit does not
`rule, rules against us on the one issue that the Board decided upon, that we
`should have a remand to address those issues.
`I don’t think it's fair to read the comment as the fact that the remaining
`issues relate to the clickable icon to say that the -- that somehow the Federal
`Circuit was pre-deciding all the various issues that we had raised in an
`argument as part of our patent owners response that the Board didn’t address
`in its first decision in which we're remanded to now address.
`I don’t see how it can be read as any other way other than the fact that
`we have these remaining disputed limitation that involve the clickable icons
`that need to be decided.
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`JUDGE COCKS: Okay, thank you.
`
`MR. WEIDER: So as the Board knows, the Board found that with
`respect to 6D, that it was common sense and there wasn’t sufficient basis for
`a motivation to combine. With respect to that provision, the Federal Circuit
`found notwithstanding the fact that there is a reluctance to use common
`sense as a basis for a motivation to combine.
`The Federal Circuit pointed to the fact that there were marketing
`articles and other literature out there that consumers wanted to have video.
`And that played a role in the Federal Circuit finding a basis to make the
`motivation to combine.
`Here, with respect to these clickable icon elements, there is no
`evidence, there is no nothing they can point to to show that consumers were
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`looking for or wanted the ability to access clickable icons as part of the
`messaging system and provide advantages like the one Mr. Klausner pointed
`to of allowing recipient to make an informed decision of whether he or she
`wanted to download the message.
`If we turn for a moment, what I want to spend a minute going over,
`I’m going to go through the petition in a little bit of detail to actually look at
`what was said as part of the petition.
`But I want to spend a minute talking about the Friedman system and
`talking about the Coulombe system and in fact, we are going to look at the
`petition. Where, in fact shows that the combination they were relying for, in
`particular for the 6F-1 element providing by the media block a clickable icon
`based on the video from the initial message they rely on a combination of
`Coulombe and Friedman and we will go through that.
`But I want to start out with Freidman for a moment. And Friedman is
`not a messaging system. That was not disputed by either expert. If you look
`at patent owner’s response at 23, we cite to both the deposition testimony
`from Mr. Klausner as well as the declaration from Dr. Surati.
`It’s not a messaging system. It's an email client. It’s designed to
`address the receipt of attachments through transport service. I know Ms.
`Liang just pointed out the fact that at the very beginning it talks about
`electronic messages can include instant messaging.
`But if you go on and read everything else that’s discussed in
`Freidman, Friedman talks about for example if you look at column 2, line 4
`it talks about exemplary embodiments of the present disclosure provides
`systems and methods for processing attachments that are received through
`one or more message transport services. The whole premise of the operation
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`of Freidman is it is receiving a communication that has an attachment
`association with it.
`And the reasons for it -- the -- when I get to what really Friedman
`meant about this less arcane structure which is something very different than
`what is being used for as far as a motivation.
`If we look for example at column 2, line 24, of Friedman, it talks
`about actually I am going to go down to line 26. Where it says there explain
`above to access an attachment and receive email message a recipient
`typically has to know that a button, icon or other element needs to be
`selected followed by numerous other steps that may be involved in opening
`the attachment.
`While these traditional methods may be adequate for knowledgeable
`or experienced issuers of electronic mail clients or programs, a more
`straightforward and less arcane management structure is desired.
`So the whole object of Friedman is I’m a recipient of a lot of
`attachments. I may be unsophisticated. I don’t know how to get to them, I
`want a less arcane structure.
`And if we take a minute now and we go to Slide 5, with was prepared by Dr.
`Surati as part of his declaration, in Friedman it receives messages that
`include attachments which can be video. It detaches the video. It creates a
`thumbnail graphic and then here is the critical part. This is what less arcane
`structure means.
`It displays them all in figure 4 of Friedman which has a screen where
`now all the attachments that I have received and I want to be able to access
`them, I have a UI interface where all these attachments are explained for me
`to be able to select the one that I am looking for. That’s a very different
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`system than Coulombe.
`If we spend for a moment and take a look at Slide 8 we will start with.
`So the messaging system in Coulombe was based upon Simple which was
`the protocol for instant messaging. When I asked Mr. Klausner if he is
`aware of any other protocols that govern messaging other than instant
`message protocol his answer was not at this moment.
`And if you go down to the next question, the bolded part comes
`directly from Simple which says that I am differous from email in common
`usage and that instant messages are usually grouped together into brief live
`conversations consisting of numerous small message sent back and forth.
`And then when I asked him about that statement in particular, he
`acknowledged the differences. Opening sentence defines instant message as
`an exchange of content between the set of participants in real time and email
`is not intended to be real time and I understand that. It’s the distinction.
`These are very different systems.
`Now we will see, we are going to go to petition in a moment but just
`quickly before we get there, if we go to Slide 7 for a moment, they placed a
`lot of emphasis on the fact that Coulombe had the word attach to it as the
`basis of making the linkage. But that’s all that Coulombe talked about.
`Coulombe didn’t have any discussion of attachments or processing
`attachments and in his deposition do you have any other basis other than the
`fact the word attach appears on the screen to support that Coulombe
`contemplates sending media items by attachments. This is all I can think of.
`Now so I’m going to go -- we will go back to Slide 2 for a moment
`and look -- and dig at a little bit more on the 6F-1 limitation. I’m going to
`spend a little bit of time, I don’t know if you have handy the petition for the
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`718? I’m going to go through this in a little bit of detail if that’s --
`
`JUDGE COCKS: We have access to that.
`
`MR. WEIDER: They have access to it. Okay. So if we first start, I
`first want to just sort of begin by laying some foundation. If we go to page
`17 of that petition, it’s clear in the petition that they're relying upon
`Coulombe as disclosing the messaging system and disclosing the media
`block.
`The media block being the part that is configured to select the format
`and message layout according to device capabilities. And in particular, if
`you go to the bottom of page 17, they're focusing on the message adaption
`engine as being the relevant part to perform the adaption of the messages.
`And now if we turn there, we are going to now go look at what
`exactly was said about the reasons for making this combination. If we go to
`page 27 of the petition, which is right under F which is dealing with the 6F
`limitations, and the second full sentence under F says Coulombe and
`Bellordre do not appear to expressly disclose a clickable icon.
`But the limitation is supplied by Friedman which discloses a clickable
`icon in the form of thumbnail graphic 525. And then it goes on to provide
`some discussion about the thumbnail graphic and then if we turn to page 28,
`the first full paragraph it says it would have been obvious to one of ordinary
`skill in the art in view of Coulombe and Friedman for the thumbnail graphic
`to be provided by the media block.
`I’m not sure how you can read this any other way that they're making
`a combination that would be obvious to combine Coulombe and Friedman to
`arrive at the limitation provided by the media block.
`It then goes on and I think this was part of the question that was asked
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`before, it then goes on to provide a variety of discussion regarding
`Freidman. It talks about, you know, as such then it would be obvious to one
`of ordinary skill to modify. I’m now reading at page 29 towards the bottom
`of the carry over paragraph.
`As such it would have been obvious to one of ordinary skill to modify
`the message adoption engine in Coulombe to form -- to perform the steps
`described in Friedman as part of adapting the initial message.
`
`JUDGE COCKS: So, Counsel.
`
`MR. WEIDER: Yes.
`
`JUDGE COCKS: Ground me here a minute. What are you asking me
`to take from all of this?
`
`MR. WEIDER: By taking from this is they are relying upon -- I was
`going to get to the motivations but to answer your question, they are relying
`upon Coulombe in combination with Friedman to arrive at the 6F-1
`limitation.
`And our point is there is no basis for making that combination. That
`you have a messaging system in Coulombe, an instant messaging system
`that doesn't even incorporate the idea of attachments.
`You have this email client in Friedman that’s using icons in order to
`make a less arcane structure which is the Figure 4 way to easily select them
`out to then say well, that would somehow have led someone to believe that
`they would have plopped that icon as part of the Coulombe system.
`There is no rationale to do that. And you can see that as we get to
`some of the further, they have the section that now is labeled when we get to
`page 30 which talks about rationale and motivation for combining it.
`
`JUDGE COCKS: Counsel?
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`MR. WEIDER: Yes.
`
`JUDGE COCKS: But hasn’t your opposing counsel somewhat
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`touched on this and said that the bridge is Bellordre.
`
`MR. WEIDER: Well, there is no -
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