Trials@uspto.gov
`571-272-7822
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`Paper # 46
`Entered: June 29, 2022
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
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`v.
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`KOSS CORPORATION,
`Patent Owner.
`____________
`
`IPR2021-00600
`Patent 10,298,451 B1
`____________
`
`Record of Oral Hearing
`Held: June 1, 2022
`
`
`BEFORE: PATRICK R. SCANLON, DAVID C. MCKONE, and
`NORMAN H. BEAMER, Administrative Patent Judges.
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`571-272-7822
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`Paper # 46
`Entered: June 29, 2022
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`KOSS CORPORATION,
`Patent Owner.
`____________
`
`IPR2021-00600
`Patent 10,298,451 B1
`____________
`
`Record of Oral Hearing
`Held: June 1, 2022
`
`
`BEFORE: PATRICK R. SCANLON, DAVID C. MCKONE, and
`NORMAN H. BEAMER, Administrative Patent Judges.
`
`
`
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` IPR2021-00600
`Patent 10,298,451 B1
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`
`
`LAUREN MURRAY, ESQUIRE
`MARK KNEDEISEN, ESQUIRE
`BRIAN MONTAG, ESQUIRE
`K&L GATES, LLP
`K&L Gates Center, 210 Sixth Avenue
`Pittsburgh, Pennsylvania 15222
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`
`
`The above-entitled matter came on for hearing on Wednesday,
`June 1, 2022, commencing at 10:00 a.m. EST, by video/by telephone.
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` A
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` P P E A R A N C E S
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`ON BEHALF OF THE PETITIONER:
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`KARL RENNER, ESQUIRE
`DAVID HOLT, ESQUIRE
`RYAN CHOWDHURY, ESQUIRE
`FISH & RICHARDSON, P.C.
`1000 Maine Ave SW
`Washington, D.C. 20024
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`
`ON BEHALF OF THE PATENT OWNER:
`
`
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` IPR2021-00600
`Patent 10,298,451 B1
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`
` (Proceedings begin at 10:00 a.m.)
` JUDGE BEAMER: Good morning.
` This is Judge Beamer. With me are Judges Scanlon
`and McKone.
` This is Apple v. Koss Corporation. IPR2021-00600.
`Patent 10,298,451.
` A few opening remarks.
` Since this is a video hearing, our first priority is
` to make sure everyone can be heard. If at any time anyone
` has difficulties or is disconnected, please speak up or, if
` disconnected, you may need to contact the team who
` originally provided you with the connection information.
` If you do drop off, try to note where things were
` being discussed at the time so we can pick up at the proper point.
` Anyone who's not speaking, please mute your mic and
` only unmute when you're speaking.
` Identify yourself when you speak so that the
` transcript reflects the speaker correctly.
` And when referring to an item on the record or a
` slide in your presentation, please specify the slide number
` or the citation so the Panel can follow along and so the
` transcript is clear.
` This may be a public line, there may be members of
` the public listening in.
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`Patent 10,298,451 B1
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` So with that, I believe petitioner has one hour, and
` patent owner has entered a LEAP practitioner request and so
` they have an additional 15 minutes on top of their hour.
` Could petitioner's counsel identify themselves.
` MR. RENNER: Thank you, and good morning, Your
`Honors.
` This is Karl Renner on behalf of petitioner, Apple,
`here with David Holt and Ryan Chowdhury as well.
` JUDGE BEAMER: And patent owner?
` MS. MURRAY: This is Lauren Murray with patent
`owner. I'm here with Mark Knedeisen and Brian Montag.
` JUDGE BEAMER: Thank you.
` So petitioner, you have 60 minutes. Would you like
`to reserve time for rebuttal?
` MR. RENNER: I would, Your Honor. 25 minutes, please.
` JUDGE BEAMER: Okay. You can begin when ready.
` MR. RENNER: Thank you, Your Honor.
` If we go to Slide 3, please.
` You'll find on Slide 3 six grounds were instituted
`in this proceeding, and as you consider them, please note
`that the challenges that were levied by patent owner were
`with respect, really, to the combinability of the references
`that are put together in the first of the listed grounds on
`the sheet, Scherzer and Subramaniam, and as a consequence,
`we plan to focus our attention primarily today on the
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`question, "Would it have been obvious for a POSITA to have
`modified Scherzer with the teachings of Subramaniam, as has
`been proposed."
` Back to Slide 2. You can see an inventory of the
`slides that we've provided for the demonstratives before
`you, and in them you can see addressed are three issues;
`hindsight, teaching away, and secondary considerations.
`These categories of issues are the type that are on record
`here in the briefing, and yet, given the focus of the
`briefing on combinability more generally, rather than
`beginning with the discussion of these particular items, we
`thought we'd take you through the combination, as we see it,
`and more organically address the items as we go through.
` Slide 7, please.
` We can see Scherzer on Slide 7, and Slide 7 helps us
`to remind ourselves that Scherzer's focus, it's really not
`in dispute, and it's to increase the reach of wireless
`internet access.
` With its service, Scherzer makes possible for a user
`the ability to gain wireless internet access through a
`secured third-party access point, and in doing so, allows
`you to increase the reach of their wireless internet access
`beyond the access points that they themselves, a particular
`user, may have.
` How does it do it? Well, upper left you see an
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`excerpt from the petitioner, and we notice it's about
`sharing. Scherzer enables a user to share the credentials
`that they have to their own wireless access points, and in
`doing so, they gain the ability to leverage other people's
`access points.
` And as an example how that works, a user of
`Scherzer's service is able to access a server that stores
`their credentials. It's an online server that stores their
`credentials. Not only the access point that it has donated
`credentials for, but those that the community of users that
`are also employing the service have donated their access
`credentials, and through access to that service, it's able
`to download and identify local nearby wireless access points
`that might not be its own but that are available to it to
`connect to the internet and to devote itself to that.
` Slide 8 we address how a user signs up or registers,
`which is an important part of today's hearing.
` Top left excerpt, two options are discussed in
`Scherzer for how this is done.
` Option 1 deals with a situation where the device
`seeking to gain access is not with internet access
`presently, doesn't have cellular or other internet access,
`and for it, Scherzer describes that you would use the mail
`service, snail mail as we like to call it; slow, unreliable,
`complex.
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`Patent 10,298,451 B1
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` Option 2, where a device does have internet access
`and it's got the ability to download things, well, it takes
`advantage of that, downloads software from a website, and
`that software enables it to communicate with wireless access
`points that are not even its own.
` Now, importantly, from Option 1, when we observe
`that option, the snail mail option, we see in Scherzer a
`recognition of the notion that some devices will, in fact,
`be offline, will not have connectivity, and yet will be
`devices that we'd like to gain or give access through
`Scherzer's service to wireless access points.
` These devices don't only lack registration with that
`service, but they lack internet connectivity itself, and as
`confirmed by Dr. Cooperstock -- and we've given a clip from
`his testimony lower left -- this option is an option -- the
`only options available in Scherzer for those devices that
`lack internet connectivity.
` Scherzer leaves them to the U.S. postal service. It
`leaves them to this slow, cumbersome, and not very easy
`solution. And while that's a constraint that wasn't
`unfamiliar to many of us who used to receive the AOL disks
`all the time in the mail, we know that by 2013 this is not
`something that POSITA's felt the need to endure.
` If we go to Slide 9, we see that here, Subramaniam
`is introduced, and like Scherzer, Subramaniam also
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`Patent 10,298,451 B1
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`recognizes the need to enhance internet connectivity by
`providing devices that lack connectivity credentials to
`secured wireless access points of third parties.
` Now, rather than rely, like Scherzer does, on snail
`mail and the U.S. Postal Service, Subramaniam leverages an
`ad hoc capability of those devices. Imagine a tablet -- not
`hard to imagine -- that isn't necessarily online, but it does
`have Bluetooth, and it leverages that to gain the access to
`credentials that are on a nearby device with whom it can
`connect, and it's highlighted in the petition and by
`Dr. Cooperstock with respect to Subramaniam's Figure 3
`that's reproduced on the right-hand side of this slide.
` Device 220, which is on the left-hand side of that
`figure, is said to possess the wireless access credentials
`that are being leveraged because it's a SmartPhone with
`internet capability, it's already got those access
`credentials, it's already using wireless access point.
`Device 240, to the right of it, lacks those same
`credentials, as well as internet connectivity.
` And what we see in Subramaniam is to enable the
`offline device, the ability to go ahead and get onto the
`internet, device 220, which maintains wireless access
`credentials, passes, by Bluetooth, those credentials to that
`device which is nearby, allowing it to take advantage.
` And like Scherzer, Subramaniam is silent, says
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`Patent 10,298,451 B1
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`nothing about the need to impose limits on sharing of the
`credentials nor encryption or other well-known methods of
`limiting utility of the credentials that have been shared.
` Rather, much like Scherzer, which once the
`credentials are given to a device, it's just trusted
`somehow, it's not really talked about securing them, a
`POSITA would appreciate from this that Subramaniam, like
`Scherzer, is leaving the POSITAs to their own devices on
`particular implementations and the need to, in fact, take
`measures to secure or otherwise limit the proliferation of
`credentials.
` Now, this aspect of Subramaniam is consistent with
`the testimony offered even by patent owner's witness,
`Dr. McAlexander that recognizes that a POSITA's facility
`with security measures of the type that would be leveraged,
`if desirable. And that's, if you're looking it, Koss 2026,
`paragraph 64. We also have it referenced, if you wanted to
`take a peek, at Slide 52.
` But essentially what it's saying is Dr. McAlexander
`is recognizing that POSITAs understand how to secure things,
`so if they desire to do so, they certainly could.
` And we see that's consistent, we believe, with the
`disclosure each of Scherzer and Subramaniam offers where
`neither one discuss the need, the desire, whether or not
`security measures are put in place. This is something that
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`Patent 10,298,451 B1
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`a POSITA can readily take advantage of if and when their
`implementation calls for.
` Slide 10 shows us that Dr. Cooperstock recognized
`that a POSITA would consider it an improvement to Scherzer's
`snail mail process to pass credentials between devices with
`ease and without a physical connection, and this is made
`possible, of course, through Subramaniam.
` And through this, a POSITA would see that the
`combination enables cellular-lacking devices, 240, to obtain
`credentials from registered devices, 220, with which they
`connect using Bluetooth.
` And this comes alive, if we look at Slide 11, in two
`examples that were put forth in the petition. Each one not
`only illustrates the combination but demonstrates advantages
`flowing from it.
` If we look at Slide 12, we look at the first of
`those two examples.
` Here, we have, on the left-hand side in the figure
`that's shown here, green 220, again, is the registered to
`the Scherzer's service, and as such, this device has access
`to an access point of another user, or its own for that
`matter.
` Now, in this example, the user seeks, as we talked a
`little bit about this already, internet access for a new
`additional device which is unregistered Scherzer service and
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`Patent 10,298,451 B1
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`which is without internet access.
` It's not hard to image, again, what we have here is
`a situation common where a user, while they have access by
`their SmartPhone, they go out and buy a new tablet. That
`tablet doesn't have internet access yet. And what do they
`do? Well, Scherzer tells us you can snail mail in
`credentials, you can manually enter them, these are
`cumbersome, difficult processes, but rather than wait for
`that, you could configure your new tablet to leverage its
`Bluetooth, per Subramaniam, to your phone and to obtain
`through that Bluetooth connection the credentials already
`leveraged by your phone. As contemplated by Subramaniam,
`this allows for an immediate access. Frankly, it's quite
`easy as well.
` Slide 13 goes through the second example, which is a
`little bit different than the first. Unlike the first, it
`contemplates that even the registered device is without
`credentials for a nearby wireless access point. For
`instance, imagine that the user is traveling or they move
`away from their home and their business. We all do this.
`We walk around the earth and we go in and out of zones that
`we are familiar with.
` Further imagine that a nearby third-party access
`points exists. It's secured, but it's also available
`through Scherzer's service.
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` Now, that access point is available to my SmartPhone
`if I'm a registered user, but if I have a brand new, again,
`tablet or an unconfigured tablet, Bluetooth only, it's not
`going to get access to that wireless access point unless we
`do something. Not very practical to wait for snail mail to
`deliver me a disk.
` Instead, what we do is we leverage the Bluetooth
`device. Again, per Subramaniam, we access that third-party
`access point based on credentials that are received from the
`SmartPhone that already has access, and off we're running.
` Slide 14 goes into greater detail here and talks in
`a little bit more through Cooperstock's testimony about the
`connectivity that can be gained for 220, that is the device
`that has been registered with the service already, to the
`application server 116 that's contemplated by Scherzer, the
`one that stores those credentials. Leveraging that
` registration it has with the service, it obtains the
` identification and the credentials of the nearby access
` point. A Bluetooth connection then is established with
` respect to device 240 offline. Those credentials are
` shared, and that device is able, through them, to register
` and gain access online.
` Slide 15.
` Now, in each example --
` JUDGE BEAMER: Counsel.
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` MR. RENNER: Please, Your Honor.
` JUDGE BEAMER: I mean, once the device 240 has the
`access point credentials that it got from device 220, why
`would it then go through the process of registering?
` MR. RENNER: That's a great question, and the answer
`to that question is several fold.
` The first of it is that that device, that tablet, at
`the moment we're talking about in the example, it's next to
`the SmartPhone. It has that Bluetooth connection.
` But equally imaginable is that that device is going
`to at some point not be tethered, if you will, or within
`Bluetooth range of that SmartPhone.
` Now, you walk away from that SmartPhone, and you've
`got your tablet still, you want online access. Depending on
`where you are, you might be near the same access point that
`you received credentials for, but you might not. You might
`be away from it, you might be away from any known access
`point and yet accessible to a Scherzer access point.
` With the registration comes downloading of the
`software. Well, that's the first step, actually. You get
`the software, you register. Now that tablet, much like the
`SmartPhone, is able to take advantage of the entire network
`of Scherzer access points and it's live.
` So the registration process is important to
`emancipate, effectively, that tablet and make it available as
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`you move around.
` JUDGE BEAMER: Thank you.
` MR. RENNER: You're welcome.
` Now, it was previously mentioned that uses, as 240
` does, of those credentials to obtain access to the application
` server and to download, and your question was quite timely,
` the software that allows it to thereafter move around.
` I'll skip further. Slide 16, please.
` Now, when evaluating the combination, we see in
` Slide 16 that the combination was identified with the
`problem in mind as realistic and appropriate. Obviously, an
`interim decision, not something that's final, but I do want
`to make a note of the fact that Your Honors had seen this
`and that was the evaluation given to it.
` I'll also note that this combination shares in some
`manner a likeness to that which is evaluated in the '00255
`proceeding where, again, the words realistic and appropriate
`were used to describe the combination involving the Scherzer
`system to expand internet touch points.
` If we look at Slide 17, there were questions asked
`in this record -- before we get to the specifics of the
`combination-type questions -- there were questions asked in
`this record about a wandering narrative, and I wanted to
`address those here.
` A lot was made of whether or not the petition
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`modified how it was dealing with devices, whether it was one
`or more users, for instance and specific.
` So I wanted to look together, and if you could load
`the petition with me, page 34 in particular would be a
`helpful reference, I think, if you can get access to it, and
`we'll talk about that in just a moment.
` While each combination we indicate could be used,
`certainly could be used, and Dr. Cooperstock reinforces the
`same, with a variety of use cases, they're not bound by
`this, our petition, nevertheless, as did the subsequent
`briefing, it wasn't unclear in the way that it described
`examples that are set forth, not only in page 34, but pages
`32 to 34. This is where you see discussion of the first
`example and that second example before we go into the
`particular claim elements.
` Each involves a single user, the examples do.
`Again, just examples, but these examples involve a single
`user of multiple devices.
` One of them has cellular or internet capability, the
`access, that's a SmartPhone, and one is then configured to
`the same as Bluetooth capabilities.
` Now, Koss would have you believe that the narrative
`has shifted, it's changed, it's evolved to address a single
`user when, in fact, at the beginning they say it did not
`have a single user indicated. But that is not the case.
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` And I'll ask you to review these pages, but I'll
`give you a couple of examples from them that will make this
`point, I hope, come true.
` If we look on page 34, the last full sentence, for
` instance. I'll read the sentence, but it's really a
` parenthetical at the end of the sentence that's going to be
` the punchline.
` It says, "Scherzer provides a solution in that
` application server 116 stores access information for nearby
` wireless access points belonging to other businesses in the
` business park (" -- here's the point -- "which the user,"
` singular, the user, "has not yet gained access to on their,"
` that is the user's, "SmartPhone or tablet."
` Page 32, this addressing the first example.
` If you look here, the heading is the first example.
` In addressing that example, the petition made clear that the
` registered user is a user's work phone. So possessive here
` is that it's the user's work phone.
` And then atop page 33, continuing in that
` discussion, it made clear that the tablet, a new device to
` be registered, would be kept "at home".
` JUDGE BEAMER: So counsel --
` MR. RENNER: Please.
` JUDGE BEAMER: -- in that first example you say "the
`registered device a user's work phone".
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` Now, I thought that your position was that devices
`weren't necessarily registered.
` MR. RENNER: Your Honor, I think our position is
`that Scherzer talks fluidly about the registration of the
`user and its devices, and it's talking about the user has
`ultimately registration, when it talks about accountability,
`tracking, and the like, but devices themselves also, they
`download the registration software, the application software,
`and they'd too register.
` So it's not terribly clear, honestly, in its writing
`exactly how that's happening, but it's clear enough that what
`it's suggesting is, to the extent that registration is
`necessary -- and we believe that to be optional in
`Scherzer -- to the extent that that happens, you can register
`the user and its devices.
` So here, you have a SmartPhone, and through the
`access by its user, and it's tethering to that, whether it's
`the user or the user and the device or the device, one way or
`the other it's registered to the service and is enabled by
`that service to have the wireless access credentials of
`third-party wireless access points.
` Does that help to clarify?
` JUDGE BEAMER: So does Scherzer talk about
`registering devices?
` MR. RENNER: Scherzer, we believe, talks about
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`registration with the Scherzer service. And the way it talks
`about that, honestly, it's certainly clear that it talks
`about registration of users. I think it also is open to the
`idea of registration of devices.
` JUDGE BEAMER: Okay. Thank you.
` MR. RENNER: Sure.
` Continuing on, we have -- and you've recognized --
` we have a SmartPhone that's associated with it, registered
` with, and available, it has, to Scherzer's service.
` And then you have a tablet, the new device, that is
` said to be kept at home -- this is on top of page 33 --
` where that new device is said to be, "Unable to connect to
` the work wireless access point, and that," and I quote, "the
` user may decide at some point to use the tablet to access
` the internet while at work."
` Again, this kind of short example tells us that the
` user who has a cell device, the work phone, also has the
` tablet. It's deciding whether or not it takes the tablet
` and keeps it at home or moves it to work, but one way or the
` other, it's the same user.
` And, in fact, the whole narrative here, all three
`pages, only talks about a user, it's never talking about a
`second user, other device users. We think fairly read, and
`certainly intended, this was to communicate an example where
`a single user was adding a device. They were buying a
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`device, they were registering a device and getting access,
`effectively, to Scherzer's service.
` And, of course, these are non-limiting examples. I
`want to make sure you see that as well. They're a first
`example and a second example, but they're to help to
`illustrate that this combination is born of a need, a need
`seen by POSITAs as foreseeable, slow connectivity or a slow
`process that's cumbersome of snail mail for registering
`devices in Scherzer that will have no online activity, no
`capability but for through the service. It's improving
`that, and you're allowing it to be done more quickly and
`with more facility.
` And each one as well leaves any detail to the reader
`and to the POSITA of how to restrict dissemination of
`credentials. This is something given to the POSITA, as I
`mentioned before. If the implementation calls for sharing
`of a credential with the user's own device, you can imagine
`the imposition of security and whatnot to be quite
`cumbersome and actually frustrating of the objectives of
`Scherzer.
` At the same time, if you have sharing of credentials
`with trusted users in a small community, you might still say
`the same thing. If you have credentials being shared in a
`broad, you know, community around the world, that's the
`intent of the sharing involved, it may be that a POSITA
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`wants to employ security measures. But these aren't things
`that even Scherzer thought were important to discuss, they
`were left to a POSITA.
` I should finally add that the combination offers a
`solution to a problem. Even if limited to particular use
`cases, even if limited to the examples, the specific
`examples we gave where it's the user's own device, even in
`that circumstance, it's no less obvious for addressing the
`problems in those use cases.
` Now, before moving to the particular arguments that
`were made by Koss in the record, I wanted to take a moment
`to highlight various relevant findings found in yesterday's
`final written decision in a related proceeding that also
`dealt with Scherzer. We discussed not too long ago Scherzer
`in great detail as it related to a combination with a
`different reference, Brown. And this is IPR 2021-00255.
` Now, Scherzer, of course, is the subject of both
`proceedings, as mentioned, and the proper interpretation of
`Scherzer is at issue and debated in both proceedings, and
`the arguments made by patent owner relating to Scherzer are
`strikingly similar, despite the fact that the combination is
`with different third-party references, and stands to reason,
`given the similarity that does exist in those combinations
`and the arguments that were chosen by patent owner.
` Now, with respect to this, we would look -- or we
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`would ask you to look at pages 22 and 23, and 16 of that
`decision for just a couple of statements that seem to inform
`the arguments that were common to the two proceedings.
`Arguments of hindsight, for instance.
` We can see in the middle of paragraph, and page 23
`of the decision, and I'll quote, "Given that one of the
`mechanisms disclosed in Scherzer for obtaining credentials
`from the server involves using a cell phone connection,
`petitioner's example whereby one device makes use of this
`capability and a second device not having cellular access
`makes use of, in this case, Brown transfer technique is
`realistic and appropriate, and one of ordinary skill would
`have had reasonable expectation of success."
` This, we believe, is directly applicable to Koss'
`contentions over the combinability of Scherzer with
`Subramaniam because they're driven, and the arguments are
`considered reasonable expectation of success here, and
`Subramaniam, like Brown, is enabling, through an ad hoc
`network, connectivity that allows for sharing of
`credentials.
` Argument 2B in our slides, if you look -- for
`instance, if you could turn with me to Slide 26, you'll see
`four arguments that were presented relating to teaching away
`itemized on that slide.
` So to our original table of contents, but these are
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`just the four, and so I'll give these to you four -- or ask
`you to reference these four for the sake of hearing items
`from the final written that are relevant.
` The argument of unfettered access in 2B2 is what's
`mentioned here on Slide 26.
` We see the first full sentence of page 23 where, in
`the final written decision, it says, "The user network in
`Scherzer can be limited to a network of "friends" where the
`prospect of sharing credentials among multiple devices is
`not a barrier."
` Again, it's a characterization of Scherzer itself,
`we think, bearing directly on the unfettered argument that
`is here. It's directly applicable, in fact, to the
`contentions by Koss that a POSITA would not find the
`combination obvious due to concerns over resulting access
`snowballing or otherwise being unfettered and concerns over
`potentially discouraging perspective wireless access point
`contributors from participating in Scherzer's service.
` Continuing, if I could, I would highlight an excerpt
`from page 16 regarding unlimited access and concerns over
`unfettered access that results from this combination.
` The final sentence there, I quote, "A collaborative
`community of users allows a percentage of bandwidth of the
`user's access point to be accessed by one or more other
`users in order to be able to use other access points when in
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`locations not within range."
` Now, this is directly applicable to the contentions
`by Koss that a POSITA would be dissuaded from the proposed
`combination by concerns over unfettered access, again, given
`the clear indication that limits can be, in fact, are
`anticipated, in fact, by Scherzer to protect itself against
`undue access.
` It says here that, "Percentage of the bandwidth
`available through an access point can be devoted."
` And similarly, we see in Koss', patent owner's
`slide 37, showcased a language from Scherzer at paragraph 16
`suggesting that, "The temporary user contribution accounts
`are established for a trial period."
` Again, what we notice here is Scherzer putting
`limits, enabling limits, for POSITAs to not only make sure
`that its access points are not overrun, but to make sure
`that no particular abusive, if there were one user, would
`have unfettered or continued access. A trial period in this
`case would be available.
` Again, that's patent owner's Slide 37 citing to
`Scherzer, paragraph 16.
` Just a couple more.
` At page 22, the first full sentence of the last
`paragraph of this page, this deals again with unfettered.
`Next one as well.
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` "Patent owner's reliance" -- it says, and I quote,
`"Patent owner's reliance on Scherzer’s disclosed use of
`media access control (MAC) addresses as part of the user
`registration process is unpersuasive given that Scherzer
`only indicates that the registration information can,"
`that's optional, it can, "include a MAC address, and there's
`no explanation in Scherzer how the MAC address is used, even
`if included."
` Now that's directly applicable, again, to the
`arguments that a POS
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