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`IPR2015-01974, Paper No. 48
`February 1, 2017
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`trials@uspto.gov
`571-272-7822
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`PALO ALTO NETWORKS, INC.,
`Petitioner,
`
`v.
`
`FINJAN, INC.,
`Patent Owner.
`____________
`
`Case IPR2015-01974a
`Patent 7,647,633 B2
`____________
`
`Held: January 5, 2017
`____________
`
`
`
`
`
`BEFORE: THOMAS L. GIANNETTI, MIRIAM L. QUINN, and
`PATRICK M. BOUCHER, Administrative Patent Judges.
`
`The above-entitled matter came on for hearing on Thursday,
`January 5, 2017, commencing at 10:05 a.m., at the U.S. Patent
`and Trademark Office, 600 Dulany Street, Alexandria, Virginia.
`
`
`
`
`a This case has been joined with IPR2016-00480, filed by Blue
`Coat Systems, Inc.
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`
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`Case IPR2015-01974
`Patent 7,647,633 B2
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`APPEARANCES:
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`
`
`ON BEHALF OF THE PETITIONER:
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`
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`ORION ARMON, ESQUIRE
`BRIAN EUTERMOSER, ESQUIRE
`Cooley LLP
`380 Interlocken Crescent
`Suite 900
`Broomfield, Colorado 80021-8023
`
`JAMES HANNAH, ESQUIRE
`AAKASH JARIWALA, ESQUIRE
`SHANNON H. HEDVAT, ESQUIRE
`Kramer, Levin, Naftalis & Frankel, LLP
`990 Marsh Road
`Menlo Park, California 94025-1949
`
`
`
`
`
` 2
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`ON BEHALF OF PATENT OWNER:
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`Case IPR2015-01974
`Patent 7,647,633 B2
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`P R O C E E D I N G S
`- - - - -
`JUDGE GIANNETTI: Welcome everyone. This is the
`final argument in case IPR2015-01974 which was joined with
`case IPR2016-00480. We will be hearing both cases today. Palo
`Alto Networks versus Finjan, Inc., is the caption of the case.
`I want to introduce the panel and then I'm going to turn
`the hearing over to Judge Quinn. We have Judge Boucher
`participating from Denver on the screen to my left and Judge
`Quinn participating from Dallas on the screen to my right. So
`that is the panel for this case. And as I mentioned, Judge Quinn
`will be presiding over the hearing. So Judge Quinn.
`JUDGE QUINN: Yes, thank you. Welcome
`everybody. First before announcing the parties and beginning, I
`notice that petitioner filed objections to a demonstrative. I didn't
`see any objections filed by patent owner. So I guess this
`comment or instruction will be addressed to petitioner. In this
`hearing there will be no speaking objections. We note what the
`objections are and we will discuss them if necessary. However,
`demonstratives are not evidence. So therefore, proceed
`accordingly.
`At this point, I want to ask if the demonstratives were
`provided to the court reporter.
`MR. ARMON: Yes, Your Honor.
`MR. HANNAH: Yes, Your Honor.
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`JUDGE QUINN: Thank you. Yes, I see nodding from
`the court reporter. So I take that as a yes too. Petitioner, who has
`the burden of proving unpatentability, may now step up and
`introduce yourselves for the record.
`MR. ARMON: Good morning, Your Honor. Orion
`Armon, Cooley, lead counsel for petitioner, Palo Alto Networks.
`I have a trial tech from Focal Point, Justin Kelly, here at counsel
`table. And my colleague, Brian Eutermoser, is behind me in the
`gallery.
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`JUDGE QUINN: Will patent owner counsel please
`make an appearance for the record.
`MR. HANNAH: Good morning, Your Honors. Nice to
`see you all again. Happy New Year. James Hannah on behalf of
`Finjan. With me is Aakash Jariwala and Shannon Hedvat.
`JUDGE QUINN: Thank you. Mr. Armon, we have
`allotted one hour for both sides. You have the opportunity to
`reserve time for rebuttal. How much time would you like to
`reserve?
`MR. ARMON: Your Honor, I would like to reserve
`20 minutes, please.
`JUDGE QUINN: Thank you. And as I stated last time
`you were with us, I'm keeping track on my iPhone. So I'll alert
`you ahead of time when you are getting close or you will hear the
`alarm go off, and then you'll know you are at your 40 minutes.
`You may proceed when you are ready.
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`MR. ARMON: Thank you. May it please the Board, I
`intend to start, unless otherwise directed by the panel, with the
`issue of claim construction today, which is in Section 3 of
`petitioner's slides, and then address the substantive validity issues
`in Section 4. And then with my remaining time, I intend to reach
`the other items covered by our slides.
`Let's turn to slide 21, please. So turning to claim
`construction first, there is one disputed claim term at issue in this
`inter partes review proceeding. That term is the entire last
`limitation of the independent claim 14 in the '633 patent. That
`limitation is shown on slide 22. Finjan proposes construction of
`plain and ordinary meaning with the additional clause that
`wherein the mobile protection code is communicated to the
`downloadable information destination without modifying the
`executable code. And that's the key issue in dispute concerning
`the claim constructions in this matter, Finjan's proposal that the
`construction include a negative limitation that prohibits any
`modification to the executable code.
`Palo Alto Networks' position is that the plain and
`ordinary meaning of the term is adequate and that there is no
`disavowal in either the claims or specification that would support
`the negative limitation that Finjan seeks to read into the claims.
`I'll start first with the claim language itself. We look at
`claim 14 here on slide 23, the yellow highlighted limitation is the
`entire limitation that Finjan seeks to have construed. The
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`language here in the claim does not include any words that would
`prohibit modification of executable code. Interestingly, the claim
`mentions first in the second named limitation receiving at the
`information re-communicator downloadable information,
`including executable code. There's nothing in that second
`limitation that indicates whether the downloadable information
`must be an entire downloadable. Neither is there anything in the
`second limitation that indicates whether the executable code must
`be -- is limited to a whole executable or a portion of an
`executable.
`If you look at the last limitation, the claim language
`refers to only one or more operations of executable code. And
`not only is it referring to operations of executable code, but they
`need not even be executed because it's the mobile protection code
`that is executed in the event that one or more operations of
`executable code were attempted. So there's nothing in the claim
`language itself that would support the negative limitation that
`Finjan seeks to read in.
`JUDGE QUINN: But counsel, that limitation does
`seem to suggest that at least one or more operations of executable
`code that are at the destination must be unmodified from those
`that were received. Whether the entire code or some portion of
`the code may be modified, I think the claim language really
`focuses on one or more operations of the executable code if those
`are the ones that will be processed by the mobile protection code.
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`So that's why I'm interested in you explaining if the claims allow
`for modification of those very operations.
`MR. ARMON: Your Honor, our view is that the claim
`language itself does not decide or answer that issue. The claim
`language only refers to one or more operations that may be
`attempted. There is no indication in the claim language itself
`whether or not those operations may or may not be modified
`operations or whether or not the overall executable code, which is
`the focus of Finjan's construction, may or may not be modified.
`JUDGE QUINN: But it seems to me that there is a
`distinguishing factor here in that the specification does refer to
`modifying the operation of the executable code, but it doesn't say
`anything about modifying the code itself. So there is some room
`to interpret the claims. If you see them logically, what you
`receive is also transmitted but at least only the one or more
`operations that you are interested in, those need to be not
`changed. It would need to be the same ones that you received; is
`that not correct?
`MR. ARMON: Your Honor, I would agree that the one
`or more operations would certainly need to be part of the
`downloadable information, which is what's recited in the claim. I
`don't agree that there's anything in the claim language that speaks
`to this question of modification. The claims simply don't
`determine the issue because the language of the claims does not
`address it.
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`JUDGE QUINN: So what would be the point of the
`mobile protection code if you have changed the executable code
`such that it's no longer in need of protection?
`MR. ARMON: Your Honor, that's an observation that
`patent owner has carried over from the District Court involving
`the Blue Coat litigation. And I think the distinction here, as
`Dr. Rubin explained during his deposition, that there is a
`difference between a wholesale modification of downloadable
`information to completely render a downloadable safe. And
`what's mentioned in the specification which are modifications
`that don't completely rewrite the functionality of downloadable
`information but instead will monitor and intercept potentially
`malicious or hostile operations. And that's what we are talking
`about here, because both the Shin and Poison Java references are
`only making modifications on the fringe, so to speak. They are
`not changing the operation of the Java applets themselves.
`I would like to turn to the specification because I think
`that's the area where we have the most guidance --
`JUDGE GIANNETTI: Before you do that, counsel, let
`me just go back to the claim. Would you agree that in the last
`two lines, see the reference there to executable code?
`MR. ARMON: Yes, Your Honor.
`JUDGE GIANNETTI: Would you agree that that is the
`same executable code that's referred to in the previous paragraph,
`that that is the antecedent for that?
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`MR. ARMON: Your Honor, I don't agree that the
`patent owner's antecedent basis argument is persuasive here.
`JUDGE GIANNETTI: Answer my question, though.
`Isn't it the same executable code?
`MR. ARMON: Yes, I think the executable code is
`referring to the downloadable information, including executable
`code.
`
`JUDGE GIANNETTI: So why doesn't that support the
`argument that it has to be the same, same code? Without going to
`the specification, just looking at the claim and applying standard
`patent law principles about antecedents, why isn't it the same?
`MR. ARMON: Your Honor, I agree that it's the same
`code, but I don't think that the antecedent basis argument
`addresses the question of modification.
`JUDGE GIANNETTI: Why not?
`MR. ARMON: Because simply referring to the fact that
`the downloadable information includes executable code and then
`referring to causing mobile protection code to be executed by the
`mobile code executer at a downloadable information destination
`such that one or more operations of the executable code, if
`attempted, will be processed is certainly referring back to the
`executable code. But it doesn't indicate whether the one or more
`operations or the executable code itself needs to be the entire
`executable code or whether or not some modification might be
`made to it.
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`JUDGE GIANNETTI: Well, if one instruction in the
`executable code were changed, would you say that this claim
`would be met? It isn't the same executable code. In other words,
`if the code that was actually processed was different than the code
`in the previous sentence, wouldn't it be an argument for why this
`claim would not be infringed if the code were changed?
`MR. ARMON: I think the question comes down to
`whether or not the problematic portions of the code have been
`changed.
`JUDGE GIANNETTI: So you interpret code here as
`not meaning a line-by-line -- all of the lines of the code. You are
`saying it's the body of code, is that what you are saying? Because
`if it's not the same code, I don't see why that doesn't support the
`argument that it can't change. It has to be the same code.
`MR. ARMON: I don't think the claim language itself
`dictates, even though there's an antecedent basis reference,
`whether the executable code would still be the same with a
`modification or without.
`JUDGE GIANNETTI: I'm not quite sure I follow that,
`but why don't you go to the specification. At least I have your
`position on that.
`JUDGE BOUCHER: Actually, can I just clarify? I
`thought you said, and I wanted to confirm, when Judge Quinn
`asked about the one or more operations of the executable code, I
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`thought you said that those could have been modified also. Did I
`understand that correctly?
`MR. ARMON: The patent specification speaks to
`mobile protection code monitoring or intercepting or even
`modifying operations of the code. And given that broad
`disclosure, those one or more operations, in our view, may or
`may not be modified. The specification simply doesn't -- the
`teachings of the specification don't foreclose modification. So in
`our view, the claim language of the one or more operations could
`refer to either modified or unmodified.
`JUDGE QUINN: But there is a difference here that I'm
`seeing where we are getting lost here. There's a difference
`between the code and then the operation resulting from the
`execution of that code. So --
`MR. ARMON: Agreed.
`JUDGE QUINN: So at the receiving end you are
`getting the code. And the mobile protection code, when it's
`executed, is monitoring the operations of that code.
`MR. ARMON: Correct.
`JUDGE QUINN: So because it is monitoring those
`operations, so I understand your position that it doesn't matter
`what the code is, whether it's modified or unmodified, as long as
`the operations are being monitored correctly?
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`MR. ARMON: Your Honor, the specification refers to
`both modifications to the downloadable itself and also to
`modifications to operations.
`JUDGE QUINN: Where does the specification refer to
`modifications of the downloadable?
`MR. ARMON: I would be happy to jump into the
`specification and speak to that. Let's turn to C, please, Justin,
`jumping quickly to the right piece. This is from Exhibit 1001,
`'633 patent, column 17, lines 51 to 53. This portion of the
`specification has been briefed by the parties.
`JUDGE GIANNETTI: Can you give me that reference
`
`again?
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`MR. ARMON: Your Honor, it's column 17, around
`lines 51 to 53, the piece that you see highlighted. This portion of
`the specification is referring to the modified import address table
`or IAT which is characterized as an interface of the
`downloadable. And what you see in this highlighted portion is
`that the specification is discussing that it's discovered, however,
`that the IAT, and again, that's the import address table, can be
`modified so that any call to an API, application programming
`interface, can be redirected to a function within the mobile
`protection code.
`If we could pull up D, please, I'm jumping to
`Figure 12A now of the patent, and you'll see that in Figure 12A
`when referring to this portion of the specification, there's a
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`reference to modifying the downloadable API. So again, this is
`an interface of the downloadable. It's not an interface of the
`client computer.
`Just to be clear that these disclosures are relevant to the
`issues in dispute for the claims, let's pull up E, please. This is
`claim 20 from the '633 patent which is referring to claim 14. It's
`a dependent claim from claim 14 which expressly recites
`modifying the downloadable interfaces of the downloadable.
`JUDGE QUINN: How are downloadable interfaces the
`executable code? It seems to me that this is part of the program
`that executes the downloadable which could be the Java Virtual
`Machine or part of the web browser. It doesn't say to me
`specifically that the applet itself or the JavaScript or the ActiveX
`component itself is being rewritten or modified.
`MR. ARMON: In the terms of the patent, Your Honor,
`I would agree that this is certainly downloadable information.
`The claims speak of downloadable information and then
`operations of the downloadable information. So this is certainly
`downloadable information. And I think your question goes to
`whether the interfaces are the portion that is executed. And I
`would agree that the interfaces themselves are essentially lookup
`tables for resource calls. So I think that it's questionable whether
`the interfaces themselves are executed, but I think it would be fair
`to conclude that the interfaces themselves are not executed.
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`And so if you look at it from that perspective, which
`would be akin to the District Court's focus on the problematic
`code as its way of rationalizing these disclosures relative to its
`construction, these would be changes to the downloadable but not
`to the potentially problematic operations themselves.
`Now, in terms of the disclosures in the specification, the
`question at issue is whether there is a clear and unmistakable
`disavowal of claim scope that would support reading in the
`negative limitation that Finjan proposes. There's other teachings
`in the specification that also speak to other types of downloadable
`modifications. And I would like to briefly touch on those. If we
`could pull up F, please --
`JUDGE QUINN: Before you move on to that, a
`question popped in my head here. Is it your contention that the
`'633 patent discloses that the API import table is part of the
`downloadable information that is transmitted to the client?
`MR. ARMON: Yes, Your Honor. And that's what's
`shown in the figure I just had up, Figure 12A.
`JUDGE QUINN: When I read column 17 and the
`description of Figure 12, it seems to suggest that this is happening
`at the client and that the import table is at the client. It doesn't
`really say that the import table is transmitted to the client with the
`executable code. Is this part of the mobile protection code, then?
`MR. ARMON: Your Honor, I do not think it's part of
`the mobile protection code. It's characterized in the specification
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`as part of the downloadable. And I agree that the teachings
`discussed here are discussions of modifications that are occurring
`when the downloadable has been installed in Figure 12. But I
`think that the import address table is unquestionably part of the
`downloadable as it's characterized in the specification.
`Jumping to F, please, this is still in the '633 patent. We
`are now in column 13. The highlighted text at the bottom of the
`column around lines 29 to 30 of column 13 mention other types
`of modifications that can be made to downloadable such as
`compression, encryption or other types of encoding.
`Now, if we could jump to G, please, Finjan's expert,
`Dr. Medvidovic, has offered sworn testimony in District Court
`proceedings that these modifications specifically with respect to
`the '633 patent are modifications to the executable code. So
`Finjan's own experts have opined that the disclosure here in
`column 13 are disclosures of modifications to that code.
`Now, Dr. Goodrich in this proceeding, another Finjan
`expert --
`JUDGE GIANNETTI: What was he testifying about,
`infringement? Was that the point, infringement?
`MR. ARMON: Your Honor, Dr. Medvidovic was
`opining in the District Court case on claim construction.
`JUDGE QUINN: Counsel, all of these things that are
`happening that you are explaining to us, how do you reconcile
`them with column 4, lines 11 through 16?
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`MR. ARMON: If we can put that up, please, that would
`be A, please, so it's up in front of everybody. So this is perhaps
`Finjan's best specification disclosure concerning this issue in
`column 4 where it states that advantageous placed systems and
`methods according to embodiments may block malicious
`operations without modifying the mobile code.
`And Your Honor, there's a couple of things I'd point out
`here. First of all, the reference here is to mobile code. The
`claims use different terms. They use downloadable information,
`operations and executable code. And so we are not talking about
`a specification disclosure that uses the exact same language in the
`claims. That creates some ambiguity. And I think you have to
`factor that in when you are considering whether there's a clear
`and unmistakable disavowal in light of the claims at issue in this
`proceeding.
`JUDGE GIANNETTI: Counsel, why are you using that
`standard? Isn't this an issue of giving these claims their broadest
`reasonable interpretation in light of the specification? Why are
`we talking about disavowals here?
`MR. ARMON: Your Honor, I characterize it as a
`disavowal because Finjan seeks to add what we view as a
`negative limitation that you cannot modify the downloadable, and
`to add that cannot modify, I think you would have to find a
`disavowal.
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`JUDGE GIANNETTI: That's why you are talking
`about the very high standard for disavowal, but isn't this a
`straightforward case of finding what this term would mean, what
`this claim would mean to a person of ordinary skill in light of the
`specification?
`MR. ARMON: I agree that that's absolutely the
`standard.
`JUDGE GIANNETTI: So maybe this is a question for
`the patent owner, but I wonder why we are really talking about
`disavowals here when we really should be talking about what's
`the broadest reasonable interpretation in light of the specification.
`MR. ARMON: Yes. And under that standard, Your
`Honor, I still don't believe that this language would support a
`construction that would include the prohibition on modification
`because the broadest reasonable interpretation should encompass
`all of the teachings in the specification, including those that teach
`modifying the downloadable information.
`One thing I would like to point to, Your Honor, to
`answer the question that Judge Quinn had raised a moment ago is
`in B, please. So when you are reading the disclosures in
`column 4, you need to keep in mind that the specification is
`emphatic that the embodiments that are discussed are not
`limiting. What you see here from column 20, lines 38 to 51, are
`the repeated, in fact, there are three repeated statements at the end
`of the specification that say again and again and again that the
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`embodiments disclosed are not limiting. The first one states that
`various modifications to the embodiments will be readily
`apparent. The second states that the present invention is not
`intended to be limited to the embodiment shown. And then the
`third, again, states that the embodiments described herein are not
`intended to be exhaustive or limiting.
`So when you look at column 4, the question you have to
`consider is, is this language about how advantageously systems
`and methods according to embodiments can block malicious
`operations without modifying the mobile code is the broadest
`reasonable interpretation of the claims that you can never modify
`the code. Respectfully, we think not, particularly in light of this
`thrice-emphasized fact that the embodiments taught in the
`specification are not limiting.
`I would like to jump into the substantive obviousness
`analysis and bring to bear this claim construction on the parties'
`positions on obviousness.
`JUDGE BOUCHER: Can I just clarify a small point?
`Did Dr. Rubin opine on this claim construction issue?
`MR. ARMON: Dr. Rubin opined on this claim
`construction issue for 50 pages of transcript. And this is an issue
`that I planned to address in rebuttal if it came up. But there was
`an argument presented by patent owner, including in a motion to
`exclude and elsewhere, that Dr. Rubin refused to testify
`concerning this issue of claim construction. And that's factually
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`Case IPR2015-01974
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`incorrect. His depo transcript shows that over a period of
`50 pages of his transcript, this is Exhibit 2022 or 2022.
`Beginning at page 93, line 12 and continuing all the way to
`page 143, line 14, Dr. Rubin testified over what must have been
`more than an hour about this issue of claim construction on
`cross-examination.
`And during that testimony he addressed the Blue Coat
`claim construction order. You would find that testimony from
`page 93 to page 106. He then was examined based upon the
`teachings in the specification. He addressed that issue from
`page 115 to page 119. He then addressed modifications through
`compression and coding and encryption from pages 121 to page
`130. Then finally, he spoke to modification of interfaces from
`page 136 to page 143. So considering the overall amount of
`testimony in the transcript, those 50 pages of testimony
`demonstrate that all of patent owner's questions about his
`understanding of the claim language were addressed.
`And interestingly, although patent owner argues that
`Dr. Rubin completely refused under counsel's instruction to
`answer any questions, not only did these 50 pages of transcript
`show that that's not true, but their own expert, Dr. Goodrich, in
`his declaration supporting the patent owner response, and this is
`Exhibit 2019, had no problem in his declaration in paragraphs 40,
`41, etcetera, in speaking about the positions that Dr. Rubin
`testified to during those 50 pages of testimony.
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`So, yes, Your Honor, Dr. Rubin did speak to this issue
`at length. And his opinion was that, a), having studied the claims,
`he didn't find anything in the claims that supported a prohibition
`on any modifications; b), he disagreed with the Blue Coat Court
`to the extent that its construction under the Phillips standard
`prohibited any sort of modifications; and c), his opinion was that
`the teachings of the specification, as we've argued, show that the
`specification is focusing on a differentiation between minor
`modifications as shown in Shin and Poison Java and wholesale
`modifications that would completely rewrite the code such that it
`would be completely safe by the time it was executed.
`Turning back to the slides, I would like to jump back to
`those, Justin, and I would like to proceed with discussion
`concerning what the references teach and why the claims are
`invalid as obvious under either construction, either the plain and
`ordinary meaning and also Finjan's proposed construction.
`One other thing I would like to mention actually before
`I go there, and I think this is important for purposes of this claim
`construction dispute, this is slide 26. Finjan's own experts in this
`proceeding are attempting to have it both ways. Both ways in the
`sense that Dr. Bims opined and agreed repeatedly, testified under
`cross-examination that when looking at Proofpoint's products, he
`found that the Proofpoint product, and this was for secondary
`considerations, he found that modification of the malicious code
`in Proofpoint's products was evidence of infringement. I think
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`that's really important. We have a situation here where Finjan's
`own expert is arguing that modification of malicious code shows
`infringement of claim 14, and so we have a patent owner who is
`arguing on the one hand for a claim construction that's narrow
`that helps it, in its view, avoid the Shin and Poison Java
`references while simultaneously within the same patent owner
`response its very own expert is arguing for inferences of
`secondary indicia of nonobviousness based upon a conclusion
`that Proofpoint's products allegedly infringe because they are
`modified. So the positions that patent owner has taken are
`internally inconsistent, and I think that's very problematic.
`Now, I would like to jump up in the time I have left, I
`have about ten minutes, to address the reasons why both Shin's
`teachings and also Poison Java's teachings render claim 14 and
`claim 19 obvious --
`JUDGE QUINN: Can we focus on Shin and this issue
`that you allege that regardless of the construction that we come
`up with for this causing limitation that Shin nevertheless meets
`the limitation. Can you focus on that.
`MR. ARMON: Yes, Your Honor. Let's pull up J,
`please. I want to focus just on the evidence in Shin so we can get
`right to it. The IAT modification teaching --
`JUDGE GIANNETTI: What slide is that?
`JUDGE QUINN: I'm sorry, counsel, what slide do you
`have on there?
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`MR. ARMON: I just pulled up and blown up Shin,
`Exhibit 1009 at page 5. I want to show you the key language. In
`order to set this up and help you understand the context here, the
`'633 patent characterizes the import address table modification --
`JUDGE QUINN: Excuse me, counsel. Shin is
`Exhibit 1009?
`MR. ARMON: 1009, Your Honor. The '633 patent
`characterizes the import address table modification as a diversion
`technique. Diversion in the sense that the mobile protection code
`is diverting a malicious operation to a safe operation using mobile
`protection code. As Dr. Rubin explained, that is exactly the same
`teaching that you have in Shin. What Shin shows at Exhibit 1009
`at page 5 is that the mobile protection code makes a class-level
`substitution in the Java applet merely by substituting references to
`class window with references to class safe window.
`If we can jump to K, it's illustrated. This is
`Exhibit 1009 at page 6, Figure 2 of Shin. What does that show?
`It shows a call coming in on the left side of the diagram in the
`before diagram at 101 that would go through the lookup table to a
`class window. And that's substituted with a class safe dollar sign
`window. That's the only modification that the class-level
`modification makes in Shin. And that modification effectuates
`the mobile protection code's protection.
`Now, the remainder of the Shin reference, and let's go
`back to the slides --
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