Trials@uspto.gov Paper No. 64
`571-272-7822 Entered: November 6, 2014
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`RECORD OF ORAL HEARING
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CARDIOCOM, LLC,
`Petitioner,
`
`v.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.,
`Patent Owner.
`____________
`
`Case IPR2013-00451
`Patent 7,587,469 B2
`____________
`
`Held: September 9, 2014
`____________
`
`
`Before: STEPHEN C. SIU, JUSTIN. T. ARBES, and MIRIAM L.
`QUINN, Administrative Patent Judges.
`
`
`APPEARANCES:
`
`ON BEHALF OF PETITIONER:
`
`
`DANIEL W. McDONALD, ESQUIRE
`
`
`Merchant & Gould
`
`
`3200 IDS Drive
`
`
`80 South Eighth Street
`
`
`Minneapolis, Minnesota 55402-2215
`
`
`571-272-7822 Entered: November 6, 2014
`
`
`
`
`
`RECORD OF ORAL HEARING
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CARDIOCOM, LLC,
`Petitioner,
`
`v.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.,
`Patent Owner.
`____________
`
`Case IPR2013-00451
`Patent 7,587,469 B2
`____________
`
`Held: September 9, 2014
`____________
`
`
`Before: STEPHEN C. SIU, JUSTIN. T. ARBES, and MIRIAM L.
`QUINN, Administrative Patent Judges.
`
`
`APPEARANCES:
`
`ON BEHALF OF PETITIONER:
`
`
`DANIEL W. McDONALD, ESQUIRE
`
`
`Merchant & Gould
`
`
`3200 IDS Drive
`
`
`80 South Eighth Street
`
`
`Minneapolis, Minnesota 55402-2215
`
`
`
`IPR2013-00451
`Patent 7,587,469 B2
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`
`
`
`ON BEHALF OF PATENT OWNER:
`
`
`DON DAYBELL, ESQUIRE
`
`
`BAS DE BLANK, ESQUIRE
`
`
`Orrick Herrington & Sutcliffe, LLP
`
`
`1000 Marsh Road
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`
`Menlo Park, California 94025-1015
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`
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`The above-entitled matter came on for hearing on Tuesday,
`September 9, 2014, commencing at 10:44 a.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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`- - - - -
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`JUDGE ARBES: Counsel for the Petitioner, you may
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`proceed on the second case. Would you like to reserve time for
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`rebuttal?
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`MR. MCDONALD: Yes. I would like to reserve 15
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`minutes for rebuttal. Thank you.
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`MR. DE BLANK: Your Honor, do you want copies of those
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`slides as well?
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`JUDGE ARBES: Why don't we wait until the end and we
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`will get them all at once.
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`MR. MCDONALD: If we could turn to slide 2, please, for
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`the '469 patent. A similar outline to what I just went through for the
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`'420, but we will talk briefly about the patent itself, summarize the
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`IPR2013-00451
`Patent 7,587,469 B2
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`decision granting the inter partes review, with the cited grounds,
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`summarize the art that we're relying on here and then go into how it
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`satisfies the claim elements, and then, finally, get through the issue of
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`why it would have been obvious at the time to combine this art to one
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`of ordinary skill in the art.
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`So, if we go to slide 3, this is Figure 1 from the '469 patent.
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`This is essentially a network system here. You see there's a central
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`server that has a communication network that can communicate with a
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`variety of remote apparatuses, and you see that these remote
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`apparatuses can be connected to monitoring devices as well. So, that's
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`kind of the core system here of the '469 patent.
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`This one is not focused on patients. You don't see anything
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`in this figure on patients, and elsewhere, it is not focused on patients
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`as well. So, just to make sure we're drawing that distinction on the
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`heels of the '420 patent, where group overview charts regarding
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`patients were of note. In this patent, that's really not a core issue.
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`So, if we go to slide 4, what that shows here is it's
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`handwritten in at the top middle there, to the left of the word
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`"Display," but it's -- you'll have to trust me on this, "microphone" and
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`"speakers" are the two elements that were added in there. And I show
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`that figure because that's really also part of the elements of the system
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`here that relate to such things, specifically regarding speech
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`recognition and conversion between audio and digital files
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`communicating to a patient and receiving information verbally back
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`from them and converting that.
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`So, if we now go to slide 5 with the core elements of the
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`claim, it's hard to put the whole claim on the slide here in a readable
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`fashion, so I have kind of paraphrased a little bit here, and we will
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`obviously go into detail, as needed, further as we go along. But
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`essentially the elements are this communications channel, the server,
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`and a primary device that receives programs from a server, it converts
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`a digital file into synthesized audio, so it takes it from digital, converts
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`it to something audible, presents that through the speaker, then gets
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`audible responses back, and then has a processor to collect data about
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`the primary device and provide a diagnosis of its performance. So, a
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`lot of things are going on with the primary device.
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`The secondary device is connected operatively to the
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`primary device, receives responses from a user and converts them into
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`a digital file through speech recognition. So, those are your core
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`components here, the primary device basically converting the digital
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`to speaker, audio out, and then the secondary device talks about a user
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`converting speech coming into a digital file.
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`Slide 6, if we can go to that. So, just briefly touching on the
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`prosecution history here, after final rejection, there were amendments
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`to specifically call out the synthesized audio transmission and speech
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`recognition limitations, but those weren't enough to get the claims
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`allowed. They were still rejected. That was also not to be considered
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`to be an advance over the prior art.
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`It was only with an examiner's amendment that the notice of
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`allowance came in, and this was not language that you see in anything
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`Patent 7,587,469 B2
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`that had originally been proffered by the applicant here. This is
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`apparently -- it may have come from a discussion, I don't know for
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`sure, but this is wording that the examiner had proposed to add to the
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`claim to make it allowable, and that's where you see the idea of
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`executing the programs to provide a diagnosis of a performance of the
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`primary device. And then it was allowed.
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`So, slide 7, then, if we can now go forward to the inter
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`partes review decision. Only certain claims of this patent are at issue
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`in this proceeding. Unlike the prior one, this is just claims 1, 2, and 5
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`through 10, on two grounds: One, the Cohen, Wahlquist obviousness
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`under 103, and the second grounds also includes Jacobs and
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`Neumann, with Cohen and Wahlquist, under 103. So, that's our art,
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`Cohen, Wahlquist, Jacobs, and Neumann. So, let's talk about that art
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`now at slide 8.
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`Here's a drawing of Cohen, a pretty basic drawing here.
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`You've got a -- it's a patient monitoring system, including speech
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`recognition capability. So, just on its face there, you can see it hits on
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`a lot of the elements of the claims that we're talking about here, but
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`you have this system, an outpatient subsystem over to the right there,
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`next to the stick figure, and then you've got this system overall -- it's
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`called a system 11, but it's also got a number of parts inside, are part
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`of it here, and also developed further in some of the other figures of
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`the patent.
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`If we go to slide 9, you'll see this is where the Board had
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`walked through Cohen to some extent, talking about how it did show
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`the patient monitoring by a telephone network 13, which was the line
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`between the box -- between the stick figure and the big box, the
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`central monitoring system 11, that was the big box, generating
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`questions with speech recognition that decodes the patient voice
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`commands, and then a voice generator that translates questions into an
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`audible voice with an answer stored in the database. All of that was
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`found in the IPR decision to be at least prima facie shown in Cohen.
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`And then if we go to slide 10, I think we show a little more
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`detailed figure here with Figure 5 from the patent, which shows the
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`patient subsystem 12, that's up at the top, that box up at the top, and
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`then the large box in the middle is the interface server 530, and then
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`the wider rectangular box at the bottom is the database server 560.
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`That's all discussed at the -- in the decision itself at page 15. That's all
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`in Cohen. So, it's kind of got this three-part system to it. So, that's
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`Cohen.
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`And then if we turn now to Wahlquist at slide 11, Wahlquist
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`is a system that has -- that's also a network with a central system with
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`remote, in this case, user computers that are communicated with. You
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`see those are people sitting at a desk there. The top person, next to the
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`word "Help Desk," that's the professional that apparently wears the
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`same clothes as the user, who is sitting at the desk down below that
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`one, but the user would typically be at a remote location from where
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`the help desk is. So, you have these communications.
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`And this one specifically goes to the idea of helping to
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`diagnose problems on the user computer through using the
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`Patent 7,587,469 B2
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`communications network here that perform -- causes diagnostics to be
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`performed on the user computer with results reported back, and that's
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`also summarized in the IPR decision granting the IPR request at pages
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`15 to 16.
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`So, let's go to slide 12 now. So, the core of the dispute here
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`seems to be with Cohen, whether Cohen and Wahlquist have these
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`particular limitations here, whether the primary device is in
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`communication with a server, with a component adapted to receive
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`programs with things like queries or instructions, number one. And
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`number two, whether the secondary device is adapted to receive input
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`responses and convert that -- in effect, that audio to digital files
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`through speech recognition. That seems to be the core of the issues
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`that we have to face today. So, we'll get to the number one issue first
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`at slide 13.
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`So, you can see why I didn't put the whole claim on the
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`slide, because this is just the one element of the claim with the
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`primary device here. It's got a fair amount of language to it, but
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`there's really not a dispute about most of this being in the cited art or
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`even in the prior art from the time this patent was originally obtained.
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`I would say the first two bullet points, the in communication
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`with a server and whether it receives a program with queries, et cetera,
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`those are the main issues in dispute here. There is not a dispute, as I
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`see it or understand it, on the remaining points there, that that primary
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`device can convert to audio and present as audio something from a file
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`and receive audible responses or that it has a processor that they can
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`collect data, and so on.
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`And also, I don't think there's a dispute at this point, in
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`particular -- and I think it's of some note here -- that this art, in
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`particular Wahlquist, has the claimed capability regarding providing
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`diagnosis of the performance of a device, and that's clearly where
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`Wahlquist is very much directed. That was the reason they got the
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`claims allowed in the first place, and now there is no dispute that the
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`art we've cited here discloses that.
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`So, if we go to slide 14, I believe this is coloring that we
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`added just to kind of help walk through what's what here in terms of
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`how Cohen matches up to the claims. So, the top part, the tan part,
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`is -- that's at the patient end of things. That's, in effect, at the
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`secondary device.
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`What you have got in green here in the middle has got the
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`components of the interface server 530 of Cohen. That has the
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`functionality of the primary device as claimed. It communicates with
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`the server. It's capable of receiving and executing programs. It's got a
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`processor for those purposes, and it sends things like questions,
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`messages, communications to the patient. And we've got specific
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`cites here to Cohen where it talks about those things or identifies those
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`particular elements.
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`Now, this particular drawing doesn't have the speech
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`recognition module. There's another version of the drawing that has
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`that, but that highlights the fact that that speech recognition module
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`doesn't have to be in any single location. Cohen teaches it can be
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`either in the server or at a remote place, especially if there's a
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`computer at the user's place. And so --
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`JUDGE QUINN: Counsel, going back to slide 14, where
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`you have identified the primary device as the interface server 530, as
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`you stated, there seems to be a dispute as to whether this primary
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`device receives one or more computer programs, including one or
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`more queries. Dealing with the diagram as you've shown here, can
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`you walk us through how this interface server 530 receives one or
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`more computer programs, including one or more queries?
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`MR. MCDONALD: Okay. I can -- the green is the device
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`that's going to get the program from the server, and the server is at the
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`bottom there with that database -- database interface. It's kind of hard
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`to read in this figure. I would suggest maybe the best way to answer
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`your question, Your Honor, is if we can go to column 8 of Cohen,
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`between about lines 30 and 58, and let's see if that helps us out here a
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`little bit, because I think in that section it's going to talk about what's
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`in that database.
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`The database is there to be accessed by this interface server
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`that we're saying is the primary device. Again, that's lines 30 to 58,
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`column 8. And so this is describing what's in the database here. So,
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`what is it that's being accessed by this processor that's in the interface
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`server?
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`So, database 24, that's in that bottom box that we're looking
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`at there, is the relational database keeping track of all the patients'
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`medical information. So, all their information is in this database. It's
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`got an ability to configure personalized interface screens, and then it --
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`at about line 44, access to database 24 through a walk-through
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`interface for which only one question at a time is asked. The patients
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`will use this interface. The ability for the provider to configure
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`personalized walk-throughs, and then the next one, the ability to
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`perform queries and reports.
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`This is, to me, the core of it here in terms of what is it that
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`we're getting out of the database. When you're getting that
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`walk-through interface that's got the one question at a time, that's
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`talking about kind of an algorithm where, okay, you ask this question,
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`we walk the patient through, we answer this question. A "yes"
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`answer, we go one way, "no," we go the other. We walk through a
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`series of questions and answers with them.
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`That's what is retrieved out of the database by that interface
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`server here, and the processor then takes that and presents that to the
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`user of the system based on what was retrieved out of the database.
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`So, that's where it's grabbing that program that will walk through the
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`things like instructions and queries sent to the patient.
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`If we go to slide 16, maybe that will -- that will kind of
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`reinforce this as well, slide 16 of our slides. So, then, we look at
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`Cohen. This computer processor 21 executing software programs,
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`carrying out those operations involved in patient monitoring. Well,
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`that's the walk-throughs that we got from the database server right
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`there.
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`JUDGE QUINN: Counsel, I can't see what's on the screen.
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`So, what are you pointing to?
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`MR. MCDONALD: Okay, sure. So, I am looking -- it's our
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`slide 16, and it's got a quote from Cohen, column 8, lines 15 to 18,
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`where it says, "The computer processor 21 is capable of executing
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`software programs, such as DBMS programs" -- database
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`management programs -- "and other programs capable of carrying out
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`the operations involved in patient monitoring." And that processor is
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`located at that interface server. So, that's where you execute programs
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`that involve patient monitoring.
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`Then the next quote we have on that same slide is from
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`column 4, lines 54 to 56, where it says, "The computer processor of
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`the central monitoring subsystem, controlled by software, sends
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`information (for example, instructions or queries) to the patient."
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`Exactly what the claims are talking about here. So, get that program
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`from the database, process it at the processor at the interface server,
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`and then present that to the patient through questions and instructions.
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`That's very explicitly taught in Cohen.
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`JUDGE ARBES: Counsel, can you point to anything
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`specific, though, that is describing this in the context of Figure 5, the
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`colored chart that you showed, where the information, the computer
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`programs would go from the alleged server 560 to the alleged primary
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`device 530? Is there anything specific that discloses that's how the
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`information flows?
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`MR. MCDONALD: Well, maybe if we could pop up
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`column 4 of Cohen to see -- because that's where it talks about the
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`processor sends information to the patient. So, I believe that -- that's
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`responsive, but it sounds like you're looking for a little more than
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`that?
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`JUDGE ARBES: There's -- there's slide 14, where you
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`show the colored version of Figure 5.
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`MR. MCDONALD: Right.
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`JUDGE ARBES: So, the computer programs have to go
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`from what you allege to be the server, device 560, to what you allege
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`to be the primary device 530.
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`MR. MCDONALD: Right.
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`JUDGE ARBES: And what you've pointed to in column 8
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`doesn't seem to specifically relate to what's in Figure 5.
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`MR. MCDONALD: Okay. Can we go to slide 10? Are you
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`in Cohen right now? Why don't you just go to Figure 5, then, right
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`now. I think it's a little easier to read without the color coding on it,
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`so that's why I'm in this version of it.
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`So, in the middle section there, 530, that is where the
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`processor is located. Now, in this particular figure, you don't see it
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`labeled as such, but that processor 21 -- maybe it's back in that Figure
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`2-A. I'm looking for the figure that would actually show the processor
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`21. 2-A? So, it's got the -- well, it's got 22-A in it. Do we have 22?
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`Oh, 21 is the big box, right. Can we turn that?
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`All right. I will try to talk about it while it's sideways here.
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`There's that larger box 21 there that I believe is the processor that it's
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`talking about. Yeah, that's the processor. When I was talking before
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`about the processor capable of executing programs, that's 21. That's
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`located there with the ASR module, with the interface module, with
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`the DTMF module, and those are the modules that are associated with
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`that middle, that big green box that we're seeing as the interface
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`server.
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`So, this is a little different depiction of the system, but that
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`processor -- and also the fact that that processor is talked about in
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`column 4 as sending information to the patient, that's also going to be
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`at that interface to the outpatient system.
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`And so, again, if we go to that Figure 5 --
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`JUDGE ARBES: So, Figure 2 is not showing the server.
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`MR. MCDONALD: No. It's a different depiction of it, but
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`it does show the processor 21 as including the DTMF interface, and if
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`you have -- ASR, and what was the third interface? Let me see if I
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`can see that.
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`JUDGE QUINN: Counsel, the way I read Cohen, Figure
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`2-A is a simplified version of the system, but it still shows database
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`24, which in the embodiment shown in Figure 5-A is within the server
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`560, the database server 560. And my understanding is you're
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`asserting that the database, which contains the walk-throughs,
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`when encompassed within the database server 560, that's the server
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`that is transmitting the walk-throughs, and then the processor 21, that
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`would then be within interface server 530, would receive those
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`programs. So, is that -- is that --
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`MR. MCDONALD: That's what I'm saying.
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`JUDGE QUINN: -- what you have described?
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`MR. MCDONALD: Right. And because 21 isn't shown
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`here in this figure, I'm trying to give you the reason why I'm saying
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`that, but the processor includes, for example, the patient interface and
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`the DTMF interface, I believe if you go back and look at that other
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`figure, number one. And number two, that the processor sends
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`information to the patient, that would indicate it's going to be up at
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`that interface with the outpatient system.
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`So, for both of those reasons, I'm saying that the processor
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`taught by Cohen at number 21 is going to be located in that interface
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`server, that middle area that we colored as green before, and it
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`retrieves the walk-through programs from the database down at the
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`bottom, but it's in the middle, and then it presents it to the patient,
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`because that's where the interface to the patient is, is in the middle
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`section of this Figure 5.
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`So, if we go to slide 17, so that's the server aspects that are
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`taught by Cohen. And then we'll talk about Wahlquist also having
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`some teachings about the queries, presenting queries to a remote
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`device and things, but also going to the diagnosis of the performance
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`of a device. So, Wahlquist specifically talks about building a
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`high-level instruction or script file. Claim 1 here doesn't require a
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`script program or file, you'll hear about that more this afternoon for
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`those patents, but I believe claim 10 here is a dependent claim that
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`does have script in it. So, Wahlquist -- that scripting teaching of
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`Wahlquist is relevant to claim 10 here.
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`JUDGE ARBES: Counsel, just to be clear, are you relying
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`on Cohen or Wahlquist for the limitation of the computer programs
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`with queries, instructions, or messages?
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`MR. MCDONALD: Well, I think we're relying to some
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`extent on both, but I think Cohen primarily, and to some extent
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`Wahlquist also teaches it. It just reinforces why one of ordinary skill
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`would look logically to Wahlquist to enhance the capabilities with
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`Cohen. So, it's kind of for both reasons, I would say. But I would say
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`Wahlquist also teaches that to some extent, but Cohen, I think, is more
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`directly to the claim limitations and all the details of the claim
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`limitations.
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`So, Wahlquist has these diagnostic tests that can either be on
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`a disk or downloaded from the central computer associated with the
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`help desk to the user computer. They might require the user to reply
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`to a prompt or they might be in kind of an automatic mode. Those are
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`both taught by Wahlquist as options. So, that's generally what
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`Wahlquist does.
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`So, we'll talk about the -- now, let's talk about the secondary
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`device. So, Wahlquist does have some aspects related to the primary
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`device, but let's talk now about the secondary twice. It's adapted to be
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`operated by the individual. It's got a user interface adapted to receive
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`input responses from the individual. That user interface is also
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`adapted to convert responses to digital through speech recognition.
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`And in the board decision, it noted that these things don't
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`necessarily all have to be located proximate to the remotely located
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`user, the person associated with the secondary device.
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`So, if we go to slide 19, just back to that color version, that
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`peach, maybe, or tannish color at the top would be the -- at least some
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`components of the outpatient subsystem, and this -- this figure here at
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`the top, it calls it out as an outpatient subsystem. That's what we're
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`saying is the secondary device required by the claim. So, that's in
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`Cohen.
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`So, if we go to slide 20, Cohen -- those figures weren't real
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`clear, you saw that patient subsystem, it didn't show sub -- the voice
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`recognition in that figure I just showed you. So, I want to talk here
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`about what's taught in the rest of the patent itself to show you why it
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`does teach that that could be located at the patient.
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`For one thing, Cohen teaches that the patient subsystem
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`might be a computer with a modem in it. Our expert talked about,
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`well, if it is a computer, it certainly could have a speech recognition
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`capability that's been well known to one of ordinary skill in the art
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`before the '469 was filed, and the Board did agree essentially with
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`that, that that was -- that that type of functionality was known to be
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`included in the computers disclosed in Cohen that would be at the
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`patient subsystem.
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`JUDGE QUINN: Well, Counsel, I mean, there's a
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`difference in our standard for instituting and what we have to do now,
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`which is to evaluate whether the preponderance of the evidence
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`supports your position. And we've been presented with
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`counter-evidence that the conversion through speech recognition in
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`Cohen is not performed in any way at the outpatient system and that it
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`wouldn't be obvious to move it there. What is your response to that?
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`MR. MCDONALD: Well, for that, Bosch relies on Figure
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`5-A, which is an embodiment that shows speech recognition going on
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`at that interface server, and there is a box there in 5-A that shows that.
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`That's one of the embodiments of Cohen.
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`But if we can go to slide 10 and see figure -- not Figure 5-A
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`but Figure 5, Figure 5 doesn't show that speech recognition module
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`there at that interface server. So, I think the point here is Cohen
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`doesn't teach it has to be located at one place. It's not shown at the
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`outpatient subsystem as a separate box here, but when Cohen teaches
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`that the patient subsystem may have that computer and shows that the
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`speech recognition does not have to be at the interface server, you
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`combine that with Dr. Stone's analysis of what one of ordinary skill
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`would understand a computer could do back before the '469 patent
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`was filed, including, clearly, speech recognition, and that's how we get
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`there, I think, number one.
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`And also, if we turn to slide 21, the other point of that is, as
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`was found in the Board's decision, that secondary device doesn't need
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`to necessarily have everything right proximate, directly acted on by
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`the individual, whether they're in a home or otherwise. And you see
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`here further discussion with Cohen, and an alternative environment
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`that the speech recognition technology is used at the central
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`monitoring subsystem to recognize the patient's verbal responses. So,
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`it's being used there. That's the other embodiment that would be
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`within the scope of these claims as the Board has construed them. So,
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`it doesn't have to be at the patient -- the outpatient subsystem, in other
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`words, to meet the claims.
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`JUDGE ARBES: But, Counsel, the outpatient --
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`JUDGE QUINN: Are you implying here that because the
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`speech recognition, some of the embodiments are shown at the
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`interface server, that part of the secondary device could include those
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`modules that are shown in Cohen in the interface server?
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`MR. MCDONALD: Yes. Yes, I'm implying that the
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`interface server, the functionalities required by the claims are certain
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`modules within that 530, that green area, but to the extent you go from
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`Figure 5 that doesn't have speech recognition, that would be the
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`interface server in Figure 5, that doesn't have the speech recognition
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`box in it. That's what we're saying.
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`Then when they go to Figure 5-A and they add the speech
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`recognition box and it's shown there physically or in the graphical
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`representation, we're saying, well, if you add that, that should be --
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`that could be considered that secondary device capability, because
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`Figure 5 shows you that the interface server has this complete
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`functionality, apart from having the speech recognition module in it.
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`JUDGE QUINN: So, I -- let me get this straight, because in
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`your petition, your position is that the secondary device, because it
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`discloses a computer, the use of a computer, that the speech
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`recognition could be located there because it would be obvious to one
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`skilled in the art to put it there.
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`MR. MCDONALD: Correct.
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`JUDGE QUINN: But now what I'm hearing is that Cohen
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`itself teaches the module that is present in the interface server and that
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`that module itself, even though it's not located at the outpatient
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`system, would be part of that speech recognition that is needed in the
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`claims.
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`MR. MCDONALD: I think both -- both teachings would --
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`are supported by Cohen, and you can get there either way. I guess
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`that's what I'm saying.
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`JUDGE QUINN: But is this position that you have, that the
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`ASR module that is in the interface server 530, that that teaches the
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`speech recognition taught by the claims, is this in your petition?
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`MR. MCDONALD: I believe it is. I'm sorry, I can't point to
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`a specific reference to that. Certainly, when we combine it, though,
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`with the other art -- maybe the best thing for me, since I don't have
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`that cite ready for you, is to go on with my minutes that I have got left
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`here and then make a couple other points, because, I'm sorry, I don't
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`have that cite handy.
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`I will note that the '469 patent itself teaches as an alternative
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`that the speech recognition can be at the central server. That's at
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`column 20 at lines 52 to 57. So, that's certainly supportive of the
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`claims encompassing that as an alternative. And it's really a design
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`choice where you put it, and that, I think, is made especially clear
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`when we get to slide 22 here and we talk about the other two
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`references that we've cited.
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`So, we've got here Neumann, is this patient monitoring
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`system with an audio channel, and that's kind of a tiny drawing here,
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`but you can see the bed with the patient in the upper left of the
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`drawing, and just to the left of that is dashed in this audio capability
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`here. So, this is a representation of Neumann that has these elements
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`with communication audio at -- with the patient.
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`And if we go to slide 23 then, Neumann specifically
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`discloses converting the speech to a digital file. I think Dr. Stone was
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`pointing out that this is pretty ordinary for one of ordinary skill, that if
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