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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MINIATURE PRECISION COMPONENTS, INC.,
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`Petitioner,
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`v.
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`EAGLE INDUSTRIES, INC.,
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`Patent Owner.
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`____________
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`IPR 2017-01403
`Patent 8,205,592 B2
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`____________
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`Record of Oral Hearing
`Held: September 7, 2018
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`____________
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`Before MICHAEL W. KIM, JAMES A. WORTH, and RICHARD H.
`MARSCHALL, Administrative Patent Judges.
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`IPR 2017-01403
`Patent 8,205,592 B2
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`JOHN S. ARTZ, ESQUIRE
`BRYAN J. SCHOMER, ESQUIRE
`Dickinson Wright
`International Square
`1825 Eye Street, N.W.
`Suite 900
`Washington, D.C. 20006
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER:
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` BEHALF OF THE PATENT OWNER:
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`JAKOB KOERING, ESQUIRE
`Miller Canfield Paddock Stone
`225 W. Washington Street
`Suite 2600
`Chicago, IL 60606
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`The above-entitled matter came on for hearing on Friday, September
`7, 2018, commencing at 10 a.m., at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia, before Julie Souza, Notary Public.
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`P R O C E E D I N G S
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`JUDGE MARSCHALL: Good morning. We're here to discuss the
`matter in IPR 2017-01403 between Petitioner Miniature Precision
`Components, Inc., and Patent Owner Eagle Industries, Inc., and this is
`reviewing patent No. 8,205,592. I'm Judge Marschall. With me is Judge
`Kim and Judge Worth. Let's start with appearances beginning with the
`Petitioner.
`MR. ARTZ: Yes. Good morning, Your Honor. John Artz on behalf
`of Petitioner.
`MR. SCHOMER: Good morning. Bryan Schomer on behalf of
`Petitioner.
`JUDGE MARSCHALL: Patent Owner.
`MR. KOERING: Good morning, Your Honor. Jakob Koering on
`behalf of the Patent Owner.
`JUDGE MARSCHALL: Well thank you and welcome. Each party
`will have 30 minutes of total argument time. Petitioner can reserve time for
`rebuttal and Petitioner you can begin when ready and please let me know if
`you want to reserve some time for rebuttal.
`MR. ARTZ: Yes. We would like to reserve five minutes for rebuttal.
`As a preliminary question before we begin, we have an issue that had been
`raised with respect to demonstrative exhibits and new samples that had been
`brought today. Is that something you'd like to address now or would you
`like me to address it during the argument, or I guess what's your preference
`of how we should deal with that issue.
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`JUDGE MARSCHALL: I would address it during the argument or
`your rebuttal. I don't want you getting up and objecting in the middle of
`Patent Owner's presentation so handle it how you wish.
`MR. ARTZ: Okay. Thank you. So, good morning. There's four
`issues that we're going to be addressing today. First, we're going to address
`the actual invention of the ’592 patent as informed by the intrinsic evidence
`the patent and file history. What you're going to later hear from Patent
`Owner is an attempt to rewrite the alleged invention of the 592 patent
`because of the prior art that's been found, but if you listen carefully to their
`story you're not going to hear any citations to intrinsic evidence. What
`you're going to hear is solely attorney argument and expert testimony,
`extrinsic evidence, that's it.
`Second, we're going to discuss what are the grounds that have been
`instituted. They've waived many issues. What's left for this Board to
`decide?
`Third, we're going to address those grounds and the two claim
`construction issues that exist and why the remaining claims are unpatentable,
`and then fourth we're going to address their new arguments and new
`evidence that shouldn't be considered, and a request to exclude same.
`So let's talk briefly. What is the invention of the 592 patent? Let's
`start with the title. The title itself says it's a noise abatement cover. What is
`that? That's an engine cover that goes within an engine compartment of a
`vehicle to help reduce noise of the engine.
`So what does the abstract say about it? The abstract says it's an
`engine cover that provides noise abatement, just like the title says, but also
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`has a high quality outer surface which is important in the automotive
`industry. They deal with class A surfaces, exterior surfaces. There's
`requirements that OEMs have for surfaces that are going to be exposed.
`The background of the 592 patent is also instructive as to what the
`invention of the 592 patent is. It goes through and identifies the prior covers
`that existed that were in the art at that time and what the problems were that
`were with them. Prior engine covers consisted primarily of multiple
`components. One component addressed the sound absorption aspect or
`benefit that was trying to be achieved and the second addressed the exterior
`or aesthetics. One was typically comprised of foam, the sound absorption
`and the aesthetics was addressed by a separate plastic piece that had to be
`assembled together, two separate pieces to form a single engine cover.
`Another example that's provided in the background is a one piece
`engine cover, Carcoustics Mini Cooper engine cover. It does have a one
`piece engine cover with a texture on it, as their expert testified, but it was
`made of a high density polyurethane foam so it didn't provide the required
`sound absorption, so it had inferior sound absorption. The 592 spec thus
`describes that the invention is an integral one piece engine cover that
`provides both noise abatement and proper aesthetics in a single part. The
`spec goes on to differentiate its unitary construction compared to the
`multiple components that were required with prior engine covers to yield
`both noise abatement and aesthetics.
`The Applicant during prosecution history similarly emphasized the
`desire to provide in a single engine cover both a medium density
`polyurethane core which provided the sound absorption and a textured outer
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`surface. That's what they argued throughout prosecution history was new
`and the Notice of Allowance makes clear that's exactly what the examiner
`thought that the patent covered when he allowed it. He makes clear that
`"medium density polyurethane with an integral outer surface is important"
`and the Board acknowledged this in its Institution decision when it said the
`592 patent differs over prior engine covers that are made of multiple pieces.
`JUDGE MARSCHALL: Is there anything in the intrinsic evidence
`that supports your construction of texture in the sense that it covers a smooth
`surface?
`MR. ARTZ: Yes, Your Honor, there is. So first the specification
`emphasizes broadly that the goal of the patent's outer surface is to provide
`appearance and beauty and also "a high quality first surface". The spec does
`indicate and provide an example, a preferred embodiment where texture can
`be imparted to the device or to the engine cover by a grained outer surface in
`a mold. But that's one example, but it contradicts and is contradiction, for
`example, if you look at figure 1. Reference numeral 12 of figure 1 identifies
`the cover as having a textured outer surface. There's no raise, there's no
`specific type of texture that's imparted in figure 1. Their expert
`acknowledged it. The only thing that's shown in figure 1 are CAD lines and
`as he acknowledged those are not anything to impart texture.
`JUDGE MARSCHALL: Isn't it possible that figure 1 doesn't depict
`the grained texture?
`MR. ARTZ: The fact that it doesn't depict any type of texture
`confirms that texture is used in the specification is not limited. It's not
`limited to a particular type of texture. In fact during prosecution history they
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`had ample opportunity to try to emphasize what the texture was. Instead
`they said the objective was to provide a high quality outer surface. But we
`also know the ordinary meaning of texture is discerned when the dictionary
`definitions makes clear when you look at the examples in both the dictionary
`definitions provided by Petitioner and Patent Owner that texture in many
`instances modified to indicate whether the texture is rough or smooth. These
`are examples submitted in the dictionary definitions. There's nothing other
`than a single example preferred embodiment that says “may” within the 592
`patent that talks about grain. There's nothing in the rest of the specification
`that mandates that the texture had any particular type of pattern, any
`particular type of feel, and to limit it to a non-smooth texture without
`anything in the specification or prosecution history to do so would be
`running it contrary to its ordinary accepted meaning as understood by a
`person of skill in the art.
`JUDGE MARSCHALL: I guess the potential problem I have with
`your proposed construction of texture is that it would seem to cover every
`surface because every surface will be smooth or rough to some degree; is
`that accurate?
`MR. ARTZ: They are stuck with the language that they chose, Your
`Honor. But what I would say is even if you were to impart some sort of
`requirement to texture over and above besides just the dictionary meaning
`it's inherent, if not expressly stated, that Polytec includes a texture.
`JUDGE MARSCHALL: But again with that approach, let's say we go
`with Patent Owner's construction you say it would be inherent. First of all,
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`was that in the petition or is that something you brought up for the first time
`on reply?
`MR. ARTZ: No, I think it was in the petition, Your -- well it's based
`in response to the assertion that they made as to what texture is. But
`certainly it's obvious, it's obvious in view of Burr or it's obvious in view of
`Polytec alone which is a ground that was instituted. As Patent Owner's
`expert testified and admitted, textured surfaces for molding were well known
`and went back hundreds of years. In automotive parts they went back 40 to
`50 years. They were also known in prior art engine covers as he
`acknowledged as set forth in the background, so applying a texture to an
`engine cover is not anything that's new. More importantly, they don't
`challenge that it's not obvious. They don't provide any evidence that there
`would be anything new to applying a texture to an outer surface of an engine
`cover. They just simply say Polytec doesn't disclose a texture, well they
`admit that Burr does. They admit that textures are well known. It clearly
`would be obvious, whether it be in view of Polytec alone or in view of Burr,
`to apply a texture to the cover of Polytec and arrive at the inventions of
`claims 1 and 9.
`JUDGE KIM: Counsel, going back to texture for a second. If you
`remove the word texture, what's the difference?
`MR. ARTZ: If we remove the word texture?
`JUDGE KIM: Sure, yes. Because (indiscernible) –
`MR. ARTZ: You mean from the claim?
`JUDGE KIM: Yes. So is there a product that it makes a difference
`whether the word texture is there? My point being is that if there isn't that's
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`kind of difficult because it is an extra word, and I understand what you're
`saying, however, we don't like practically.
`MR. ARTZ: And I'm not trying to remove the word texture. We're
`taking the definition of texture as informed by the arguments that they made
`throughout prosecution history that says this is an automotive part. This is
`an automotive part that has a textured outer surface which they defined in
`prosecution history and never limited to being of a particular type that has an
`enhanced beautiful, high quality outer surface as --
`JUDGE KIM: Okay. Let me put it a different way. Is there any
`surface that's not textured?
`MR. ARTZ: Their expert said no --
`JUDGE KIM: Okay.
`MR. ARTZ: -- unless you take steps to, as part of the molding
`process, to polish the mold to make it smooth and that's the point of why
`Polytec teaches, if not inherently or expressly, a texture because the normal
`molding process of a plastic part is going to yield a texture of some sort. It's
`going to replicate what the inner surface of the mold is so unless you take
`steps to actually remove it and make it entirely smooth it's going to have a
`raised or rough texture of some variety.
`JUDGE KIM: That's not really getting to my point.
`MR. ARTZ: I'm sorry. Maybe I'm not understanding the question,
`Your Honor.
`JUDGE KIM: Sure. Like, okay, from what I understand from your
`arguments what you're saying is essentially any part made by a mold is
`textured?
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`MR. ARTZ: Correct . Unless you take steps -- any part made by a
`mold is textured, correct.
`JUDGE KIM: Okay.
`MR. ARTZ: But not any part made by a mold needs to have a
`beautiful first quality automotive class surface which is what they argued
`during prosecution. There are steps that need -- there's OEM specifications
`which is what this patent is and what person of skill in the art would
`understand the term textured outer surface to mean in connection with the
`592 patent. So, yes, every surface would have a texture but not every
`surface would have a textured outer surface as defined by Applicant in the
`592 patent, namely that not every part would have a automotive class surface
`which those are defined within the industry and spec from OEMs as to what
`that is.
`JUDGE KIM: So that's what you're saying is that based on OEM
`specs, you could differentiate a part based some have a textured surface,
`some not -- don't, with the dividing line being the OEM specs?
`MR. ARTZ: That's not what I'm -- but that's what the prosecution
`history has defined the word texture to be but, again, if texture requires a
`raised surface I don't think it matters because there isn't any dispute that
`applying a textured surface as Patent Owner has defined it to the cover of
`Polytec is clearly (indiscernible), it's not anything that's new.
`JUDGE KIM: I may agree with you but you're also arguing the
`construction pretty vigorously which is why I'm wondering why it matters.
`MR. ARTZ: I'm arguing it because I think that that's what they said
`during prosecution history, but in all concession if Your Honor wants to say,
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`Mr. Artz, your position on texture it takes a word out, it flies in the face of
`what we think that texture means, I'm not going to jump up and down and
`scream. At the end of the day the patent's invalid regardless of which
`construction that you adopt.
`JUDGE KIM: Okay. Thank you.
`MR. ARTZ: I'm just trying to be true to what I believe the intrinsic
`evidence tells me that the word texture is. They had every opportunity to
`emphasize that texture is some sort of pattern but they didn't and maybe the
`reason that they didn't because they knew it's not differentiating and maybe
`that's the answer and we made it more complicated unintendedly but at the
`end of the day texture is on engine covers and not anything that's new.
`JUDGE WORTH: Just to follow up on that. You have presented
`three different ways to arrive at a construction. One might be a disclaimer
`that you're arguing based upon everything that was said in the patent or
`during prosecution, and a second one appears to be what an expert said in
`this proceeding, and a third would be based upon specifications that were
`known. If you had to pick one, which is it?
`MR. ARTZ: Because I'm not understanding -- I don't think I'm
`arguing a disclaimer. So if you can tell me what you believe the argument is
`that I'm -- what I am suggesting is is that we're looking to construe what this
`means and I'm looking to the prosecution history that provides support that
`they didn't limit the term texture to a particular type of texture. I don't
`believe that that's a disclaimer, I believe that's looking to the intrinsic
`evidence to help me understand what this term means.
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`JUDGE WORTH: Okay. So if choice A is "what they said" or
`whatever your quote was, what they said, choice B is expert testimony in
`this proceeding and choice C is specifications from manufacturers, which is
`your preferred?
`MR. ARTZ: It's A, it's the intrinsic evidence. There's nothing within
`the patent or the file history that limits texture. That's my main argument
`relying on the intrinsic evidence. The other things just simply provide
`support.
`I'll jump quickly to embedded protective coating which is the next
`term that's really in dispute because there's really only two terms that are in
`dispute, texture that we've talked about and embedded protective coating.
`Patent Owner's BRI of this embedded protective coating is a protective
`coating that is incorporated and firmly fixed onto the surface of the engine
`cover and this is consistent with what the 592 patent tells us its objective is,
`is to have an engine cover that's of a single piece construction, i.e., an
`integral part.
`Again, the 592 patent distinguished its one piece engine cover from
`multiple piece engine covers and you're going to see also in their papers they
`did the same thing initially as well. The 592 patent provides some examples
`of what constitutes an embedded coating as used in the claims. First it talks
`about an IMC, an in-mold coating which they say is urethane based paint
`that's applied to the surface of the mold and is imparted to the part during the
`process.
`Patent Owner's expert agrees that IMC is an example in the
`specification of an in-mold coating. The specification also provides another
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`example of what an in-mold coating is, a urethane spray skin. That's also
`applied to the surface of the mold and imparted to the outer surface of the
`part during the process. So they apply these to the outer surface of the part,
`they make it on to the outer surface of the part and the part is emitted from
`the mold as a single unit. That's what the 592 patent means when it talks
`about embedded protective coating and that's consistent with the plain and
`ordinary meaning of the term but it's also consistent with what happened
`during prosecution history.
`When the initial claims were presented that required an embedded
`protective coating, the examiner rejected them based on the Woolover
`reference which was an engine for a marine, for a boat that had a cover that
`had a urethane or thin film skin on the surface and the examiner said that
`thin film skin satisfies the embedded protective coating. Patent Owner didn't
`challenge that. They agreed that that disclosed an embedded protective
`coating and instead decided to challenge patentability on other things.
`JUDGE MARSCHALL: Do all urethane coatings in this art
`inherently produce a chemical bond between the coating and the foam?
`MR. ARTZ: Absolutely. And that's set forth, support for that's from
`Dr. Wagoner in his expert report that says that as well. Interesting, so we've
`talked about what the examples of the embedded coating are in the 592
`patent, interestingly the Polytec references teaches an engine cover that has
`the same options for its enhanced design surface. It talks about "surface
`treating the foam body for instance using in-mold coating IMC or PU spray
`skin", the same example set forth in the 592 patent for an embedded
`protecting coating. Polytec also emphasizes that its engine covers integrate
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`the design surface to the foam body, noting "and not as usual as a separate
`plastic part". Again, Polytec just like the 592 patent talks about putting its
`coating integrated to the surface such that it's a unitary engine cover as
`opposed to having multiple pieces that need to be assembled.
`JUDGE MARSCHALL: What about Polytec's reference to multiple
`layers? How do you read that passage?
`MR. ARTZ: Well, Polytec talks about multiple layers. It doesn't talk
`about multiple parts. Every engine could have multiple layers depending
`upon how you get to it in this one layer being the foam and the other being
`the protective coating. This is a English translation but it's clear that there
`are aspects in Polytec that talk about two pieces, those are the later figures,
`and then the earlier figures talk about it being integrated.
`JUDGE MARSCHALL: Now does Polytec disclose a urethane based
`paint? I believe you said that in your petition and Patent Owner took issue
`with the cites you were using for that (indiscernible)?
`MR. ARTZ: It discloses a urethane based skin or spray skin. Polytec
`does not specifically emphasize or articulate what the chemical composition
`is of the paint, it just says that --
`JUDTGE MARSCHALL: Then how do we know? Would we know
`that there would be some inherent chemical bonding with the paint?
`MR. ARTZ: Well polyurethane based paints particularly to provide
`protection or to provide discoloring for a class A surface were well known in
`the industry as set forth in our expert report from Dr. Wagoner.
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`JUDGE MARSCHALL: Right, that might go to obviousness. I'm
`just trying to understand your inherency argument, if it's limited to the
`spray-ons or if it also includes the in-mold coating paint.
`MR ARTZ: Well I don't think that there is any -- if you're attaching
`or putting any type of paint, whether it's a polyurethane or any other paint
`onto the surface of the mold that makes it onto the engine cover, it's still
`going to be bonded to it. There's no requirement that it be of the same
`material to have this -- there's nothing in the specification that mandates this,
`there's no technical thing that they've provided that makes that required.
`JUDGE MARSCHALL: Chemically bonded as well or just bonded in
`general?
`MR. ARTZ: I don't know that there's -- our expert said, Wagoner,
`that an in-mold coating, he didn't specify the material, would require a result
`in a chemical bond between the material, the paint, whatever it is, the in-
`mold coating as well as the foam body and in rebuttal I will give you that
`exact cite.
`JUDGE MARSCHALL: Now you mentioned obviousness in passing
`and in your reply you have a whole section devoted to obviousness of this
`limitation in the event we went with Patent Owner's construction and didn't
`buy your inherency argument. Did that obviousness argument appear in
`your petition at all?
`MR. ARTZ: Oh, absolutely it did. We had in view of Polytec alone,
`Your Honor. Oh, under their construction, I'm sorry.
`JUDGE MARSCHALL: Right.
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`MR. ARTZ: No. This is in direct response to their proposal that they
`provided a broadest reasonable interpretation, our view is unreasonable and
`unforeseeable so we've taken the deposition and we had the evidence in the
`expert report that we can point to that cites that even under their construction
`that this is obvious. We're not required I don't believe to address every
`foreseeable construction. We're entitled to respond to arguments that they
`have made and we've done so with evidence within the record, and the
`citation to which I was referring is on page 30, paragraph 96 of Dr.
`Wagoner's declaration. That says, and this is with reference to the 586
`patent,
`"Because in-mold coatings are formed simultaneously with the
`substrate they are chemically bonded integral part of the composite."
`So we don't need even an obviousness or inherency argument with
`respect to Polytec because Polytec expressly discloses a chemical bonded
`from an in-mold coating paint to a foam surface.
`I guess the last thing I would like to address, Your Honor, is evidence
`and exhibits that they've brought here today in samples and then
`demonstrative exhibits that they propose to add. So they've brought samples
`here that have never been introduced, that are brand new and they've
`indicated that they propose to use them. They let us know that, we objected
`and the Board provided some guidance again as to what is proper for
`demonstrative exhibits. I don't see any basis on which these samples add
`anything, aren't new arguments, or there were no samples period that were
`ever introduced. So we don't need to say that these are similar to other
`samples because there weren't any.
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`Secondly, as to their demonstrative exhibits. They have new photos,
`in the first six or seven of the first slides are new photos. A video that's
`never been produced. The video purports to show a method of molding.
`Interesting that method of molding arguably, if anything, would be relevant
`to claim 13, the method claims to which they don't challenge. I don't see any
`basis by which they could argue except to try to create new arguments to
`support their new claim constructions that weren't present and thus isn't
`appropriate.
`They've also tried to advance new challenges. They didn't challenge
`Dr. Wagoner's qualifications in the initial Patent Owner response. They
`made some challenges although they say they're not trying to exclude him,
`but they just don't want you to consider his testimony, I'm not sure how
`that's any different, and now they're raised a new challenge in these
`demonstrative exhibits. It's not appropriate. It's not what the purpose of
`these "demonstrative exhibits" are for, the briefing is done, it's not
`appropriate. I reserve the rest of my time for rebuttal, Your Honor. Thank
`you.
`
`MR. KOERING: Good morning. As I said before, my name is Jakob
`Koering. I've actually got here in the audience with me today Mark Arthurs
`who is one of the three inventors and one of the three co-owners of Eagle
`Industries, and he's here for the same reason that I am, that this is an
`important technology to Eagle, it's important to their business and it's
`important to the success of their business and as the declaration of Keith
`Byer told us in the Patent Owner initial response the invention has been well
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`received in the industry and has led to Eagle's success. So we thank you in
`advance for your time.
`I'm going to focus on two issues and I think these are the two issues
`that are the most important here. The first is what is apparently now an
`agreed understanding of the meaning of an embedded protecting coating and
`I'm going to talk about what that means in a second, and then I want to talk
`about how that agreed meaning applies to the Polytec patent.
`Specifically, in Petitioner's reply they've stated the position now that
`they believe that the embedded protective coating leads to the conclusion
`that there is a single layer structure in the resulting product. That's their
`statement in their reply, and the reason that's important is because Polytec
`explicitly lists itself as a multi-layer product. Now because an embedded
`protective coating is listed in every single one of the at issue claims, claims 1
`to 12, the fact that Polytec is a multi-layer product and the fact that there's an
`agreed meaning of embedded protective coating means that we can confirm
`the patentability of all those claims without addressing any other issue. Now
`we believe there are other reasons as well, but we think that's a really
`important issue that we should be addressing today. So --
`JUDGE MARSCHALL: Can you just point out where in the reply
`they argued that the construction is a single layer?
`MR. KOERING: Sure, and let me point you to pages 7, 8 and 17 of
`their reply and I'll read a quote from page 17 where they say,
`"The embedded coating means that the coating is incorporated into
`and an integral part of the engine cover as distinguished from the two piece
`engine covers in the prior art."
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`What they're talking about there is that if you've got two layers that
`are integrated and incorporated in each other and it's differentiated from two
`layers that are just connected to each other, they're talking about a single
`layer structure.
`JUDGE MARSCHALL: Yes. They don't use the phrase single layer
`though, right?
`MR. KOERING: Not in that section. But at page 8 they refer to the
`fact that the specification of the 592 patent makes clear that the embedded
`protective coating for an engine cover, it simply refers to a coating resulting
`in a single piece construction, i.e., an integral part, and so --
`JUDGE MARSCHALL: Single piece but not single layer, correct?
`MR. KOERING: They're using the term single piece. We believe
`they have the same meaning here.
`JUDGE MARSCHALL: What about their argument that a single
`piece or one part can have multiple layers and therefore Polytec's teaching of
`multiple layers does not mean that it's made up of multiple parts?
`MR. KOERING: Well, first of all I think that there's no evidence of
`record to actually support that. The evidence of record here comes from Dr.
`Herrmann who took a look at the Polytec reference and he said each and
`every single one of the methods that were disclosed and relied upon by
`Petitioner, the back-foamed thermoformed film, the PU spray skin and cast
`skin and the IMC, without specifying the material each one of those can
`result in a multi-layer construction according to the only evidence of record
`on this.
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`Petitioner's original position on this I think may help understand why
`there isn't any evidence on their side and that's because if you take a look at
`their original petition, their argument was that the term embedded protective
`coating required that the coating be in intimate contact with and adhered to.
`So they were talking about in the original petition that the two layers are
`adhered to each other, that they're not incorporated, they're not integrated
`with each other, they're just glued together and that's at, by the way, page 10
`of their original petition.
`This, by the way, was the same definition that their expert used. If
`you look at paragraph 167 of his declaration he says -- it's either 167 or 168 -
`- he says that an embedded protective coating requires the layers to be in
`intimate contact with each other and adhered to each other. By definition
`that means that there's two layers and they're glued together.
`Now why is this important? Because Petitioner's expert in identifying
`why he believed that there was an embedded protective coating in Polytec,
`the only argument that he said was they use similar manufacturing methods
`and this is a critical point and this is why it's important to understa
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