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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DAIMLER AG and JAGUAR LAND )
`ROVER NORTH AMERICA, LLC, )
`et al., )
` ) Case Nos.
` Petitioners, ) IPR2018-01203
` ) IPR2018-01211
` vs. ) IPR2018-01214
` )
`BLITZSAFE TEXAS, ) Patent No.
` ) 7,489,786
` Patent Owner.
`--------------------------
`
` PTAB CONFERENCE CALL
` Friday, August 10, 2018
`
`Reported by: Stacey L. Daywalt
`Job No: 146393
`
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`Patent Owner Blitzsafe Texas, LLC – Exhibit 2001
`Daimler v. Blitzsafe, IPR2018-01214
`Page 1
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`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DAIMLER AG and JAGUAR LAND )
`ROVER NORTH AMERICA, LLC, )
`et al., )
` ) Case Nos.
` Petitioners, ) IPR2018-01203
` ) IPR2018-01211
` vs. ) IPR2018-01214
` )
`BLITZSAFE TEXAS, ) Patent No.
` ) 7,489,786
` Patent Owner.
`--------------------------
`
` PTAB CONFERENCE CALL
` Friday, August 10, 2018
`
`Reported by: Stacey L. Daywalt
`Job No: 146393
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`Patent Owner Blitzsafe Texas, LLC – Exhibit 2001
`Daimler v. Blitzsafe, IPR2018-01214
`Page 1
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`Page 2
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` Friday, August 10, 2018
` 2:00 p.m.
`
` PTAB Conference Call, held before
`Administrative Patent Judges Miriam L. Quinn,
`Thomas L. Giannetti and Jameson Lee, before
`Stacey L. Daywalt, a Court Reporter and Notary
`Public of the District of Columbia.
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`Ex. 2001 - Page 2
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`Page 3
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`A P P E A R A N C E S:
`(All appearances are telephonic)
`
` LATHAM & WATKINS
` Attorneys for Petitioner Jaguar Land Rover
` 555 Eleventh Street Northwest
` Washington, DC 20004
` BY: JONATHAN STRANG, ESQ.
` MATTHEW MOORE, ESQ.
`
` QUINN EMANUEL URQUHART & SULLIVAN
` Attorneys for Petitioner Daimler
` 51 Madison Avenue
` New York, NY 10010
` BY: JAMES GLASS, ESQ.
` SEAN GLOTH, ESQ.
`
` BROWN RUDNICK
` Attorneys for Patent Owner
` 7 Times Square
` New York, NY 10036
` BY: VINCENT RUBINO, III, ESQ.
` TIMOTHY ROUSSEAU, ESQ.
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`Ex. 2001 - Page 3
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` ADMINISTRATIVE PATENT JUDGE: All 02:00
`right. Let's begin. 02:00
` This is a conference call concerning 02:00
`IPRs 2018-1203, 2018-1211 and 2018-1214. 02:00
` With me are Judges Tom Giannetti and 02:01
`Jameson Lee. And I am Judge Miriam Quinn. And 02:01
`we've asked that the parties for these three 02:01
`proceedings appear, with Petitioners being 02:01
`represented by lead counsel, and Patent Owner, 02:01
`at least backup counsel should be present. 02:01
` We're going to start with requesting 02:01
`that the Petitioners make their appearance on 02:01
`the call, starting with the Petitioner for Case 02:01
`1203. 02:01
` MR. ROUSSEAU: Your Honor, if I may, 02:01
`this is Tim Rousseau for Patent Owner. 02:01
` We also have a court reporter on the 02:01
`line. I don't think she's begun transcribing 02:01
`yet. 02:01
` But would you like her to do that 02:01
`before -- after we make our presence known? 02:02
` THE REPORTER: Sorry. This is the 02:02
`court reporter. I did begin. 02:02
` MR. ROUSSEAU: Okay. Great. 02:02
`
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`Ex. 2001 - Page 4
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`Page 5
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` I apologize, Your Honor. 02:02
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:02
` Petitioner for the 1203 case? 02:02
` MR. STRANG: Good afternoon, Your 02:02
`Honor. This is John Strang for Petitioner 02:02
`Jaguar Land Rover. 02:02
` And with me I have lead counsel, 02:02
`Matthew Moore. 02:02
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:02
` Who do we have for the Petitioner 02:02
`from 1211 and 1214? 02:02
` MR. GLASS: Thank you, Your Honor. 02:02
`This is Jim Glass for Petitioner Daimler. 02:02
` And with me on the phone as well is 02:02
`Sean Gloth. 02:02
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:02
` And for Patent Owner, who do we 02:02
`have? 02:02
` MR. RUBINO: Your Honor, for Patent 02:02
`Owner, you have Vincent Rubino from Brown 02:02
`Rudnick. 02:02
` And with me also from Brown Rudnick 02:02
`is Tim Rousseau. 02:02
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:02
`
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`Ex. 2001 - Page 5
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`All right. 02:02
` Thank you all for being able to join 02:02
`us for a call in such a short notice, but we 02:03
`did want to address certain issues that are 02:03
`important to address early on in the case so we 02:03
`have time to make the necessary corrections. 02:03
` We have petitions in the 1203, 1211 02:03
`and 1214 case. They are all different 02:03
`Petitioners. 02:03
` So before we get into the specifics 02:03
`of each case and the reasons that we are here, 02:03
`I wanted first to ask Mr. Strang and Mr. Glass 02:03
`if you object to having this call together to 02:03
`discuss all three cases together today. 02:03
` MR. GLASS: This is Jim Glass, Your 02:03
`Honor, for Daimler. 02:04
` No objection at all from our end. 02:04
` MR. STRANG: And this is John Strang 02:04
`for Petitioner Jaguar. 02:04
` No objection on our end either, Your 02:04
`Honor. 02:04
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:04
`Thank you. 02:04
` So let's start with the reason why 02:04
`
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`Ex. 2001 - Page 6
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`we've called you all on this morning. The 02:04
`1203, 1211 and 1214 petitions, in the claim 02:04
`construction section of the petition, include 02:04
`portions that are referring to exhibits or 02:04
`documents that are extraneous to the petitions 02:04
`for addressing either the petitions of 02:04
`Petitioner concerning claim construction or the 02:04
`reasoning supporting the claim construction 02:04
`that has been advanced. 02:04
` In particular, the 1203 case, which 02:04
`is the petition which is 82 pages, it contains 02:04
`an extra claim listing in the appendix, which 02:04
`is interesting and useful. But we recognize 02:05
`also that it refers to means plus function 02:05
`positions that are on Exhibit 1015, and it 02:05
`refers and incorporates citations of the expert 02:05
`concerning those claim constructions as well. 02:05
` For the 1211 and 1214 cases, those 02:05
`petitions are also over 80 pages. They are 02:05
`close to the 14,000 word limit. Does not 02:05
`contain any index of claims, so it's very 02:05
`difficult to know what claim limitations you're 02:05
`addressing without that index. And it includes 02:05
`means plus function terms that are not 02:05
`
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`Ex. 2001 - Page 7
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`identified and referred to in Exhibit 1017 and 02:05
`through the expert declaration, who also 02:05
`incorporates Exhibit 1017. 02:05
` So it seems to us that at a minimum 02:05
`in these sections of claim construction that 02:06
`the petitions are incorporated by reference an 02:06
`exhibit that is necessary to understand and 02:06
`render a decision on institution, specifically 02:06
`to identify what are Petitioners' claim 02:06
`construction positions. 02:06
` So with that situation as I have 02:06
`expressed it to you, we have the concern about 02:06
`the petition incorporating by reference 02:06
`improperly exhibits that are not in the 02:06
`petition and that the correction of 02:06
`incorporation by reference may cause an issue 02:06
`with either exceeding the word limit or 02:06
`circumventing our rules on what is proper in 02:06
`the petition. 02:06
` With that, I would first like to 02:06
`hear from Petitioner of 1203, Mr. Strang. 02:06
` Do you have any positions as to how 02:07
`we can correct these issues as we've addressed 02:07
`them today? 02:07
`
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`Ex. 2001 - Page 8
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` MR. STRANG: Thank you, Your Honor. 02:07
`This is John Strang for Petitioner Jaguar. 02:07
` We are about 700 words under the 02:07
`word limit, not including the figures, of which 02:07
`the annotations that we added to the figures 02:07
`were only about 37 words. So we have plenty of 02:07
`room if we need to incorporate any additional 02:07
`reasoning. 02:07
` As far as the exhibits that we cite, 02:07
`the first one we cite is the board's decision. 02:07
`We gave it to the board as Exhibit 1015. And 02:07
`like citing a case, we're citing a legal 02:07
`conclusion there. 02:07
` And it's our position that while 02:07
`we're more than willing to incorporate the 02:07
`board's reasoning into that, that the board is 02:07
`not required to construe any terms unless -- 02:08
`except as needed to resolve the controversy 02:08
`between the parties, and that is well settled 02:08
`Federal Circuit law. So we see that as more of 02:08
`a case cite. 02:08
` So there was no intent there to try 02:08
`to add any additional words to the board. Just 02:08
`the opposite. We're relying on a previous 02:08
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`Ex. 2001 - Page 9
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`board decision as pretty much settled law on 02:08
`those terms. 02:08
` On the means plus function terms, we 02:08
`referenced in Exhibit 1016, but we incorporate, 02:08
`literally incorporate, word for word, the 02:08
`function and the structure corresponding to 02:08
`that function word for word out of the exhibit. 02:08
`The exhibit has very little beyond that as far 02:08
`as the additional reasoning goes. But if it 02:08
`would make it easier for the board and the 02:08
`board deems it necessary, we would appreciate 02:08
`the opportunity to literally incorporate the 02:08
`needed words that are missing from that, Your 02:09
`Honor. 02:09
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:09
` So the concern arose because, while 02:09
`you include the construction for the term, you 02:09
`do refer to, in the paragraph that introduces 02:09
`those terms, that you are adopting also the 02:09
`reasoning behind those constructions, and there 02:09
`is no reasoning provided in that section. 02:09
` So that's something that needs to be 02:09
`in the petition. It needs to be in there in 02:09
`words, not pointing to Exhibit 1016. 02:09
`
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`Ex. 2001 - Page 10
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` Whether 1016 has it or not, that's 02:09
`not the scope of this call. It's about whether 02:09
`the claim construction positions that are in 02:09
`the petition and addressed in Exhibit 1016, 02:09
`that that information really should not be in 02:09
`an exhibit. It should be in the petition if 02:09
`you want us to review it. 02:09
` MR. STRANG: Understood, Your Honor. 02:10
` It was not our intent to evade any 02:10
`word limits by doing this, and that's why we 02:10
`put the constructions right there, as required 02:10
`by 37 CFR 42.104, which states to identify the 02:10
`structure corresponding to the function, which 02:10
`is what we did. 02:10
` It's our position that Blitzsafe 02:10
`would agree with these, as they have in the 02:10
`past. So the additional reasoning that is 02:10
`beyond that in Exhibit 1015, there isn't any. 02:10
` So at worst, we would seek to strike 02:10
`the words "and reasoning," and simply add the 02:10
`cites to the patents that have -- instead of 02:10
`citing Exhibit 1015, cite the portions of the 02:10
`patents themselves that have the structure. 02:10
` ADMINISTRATIVE PATENT JUDGE: Yeah. 02:10
`
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`Ex. 2001 - Page 11
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`Page 12
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` And how about the citation to the 02:10
`expert declaration for a similar proposition? 02:11
` MR. STRANG: Your Honor, we're in 02:11
`the -- we would have the same position on that. 02:11
` We would appreciate the opportunity 02:11
`to correct any improper incorporation, which -- 02:11
`because none was intended. And to the extent 02:11
`that there's reasoning in the expert 02:11
`declaration, we would appreciate that and would 02:11
`recertify our word count, Your Honor. 02:11
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:11
` MR. STRANG: We would like, Your 02:11
`Honor, some additional direction on in 02:11
`particular which citations you're seeing as 02:11
`improper to the Strawn declaration. 02:11
` ADMINISTRATIVE PATENT JUDGE: 02:11
`Particularly, Page 14 of your petition. 02:11
` MR. STRANG: Where it says "car 02:11
`stereo," Your Honor? 02:11
` ADMINISTRATIVE PATENT JUDGE: Yes. 02:12
` If there's anything in the expert 02:12
`declaration, it should come in in the petition. 02:12
`It should just be in the petition for claim 02:12
`construction. 02:12
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`Ex. 2001 - Page 12
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`Page 13
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` So I don't want to see citations to 02:12
`the expert declaration on claim construction. 02:12
`And all of your arguments are on the expert 02:12
`declaration. That's our position. 02:12
` Whether it is or isn't, you can 02:12
`review that and revise it as needed. If it 02:12
`doesn't need revision, then it doesn't. 02:12
` MR. STRANG: Thanks, Your Honor. 02:12
` I think in this case our argument is 02:12
`primarily on Page 15, the following text, where 02:12
`we cite directly to the specification. But we 02:12
`appreciate the ability to double-check that and 02:12
`make sure that we did not inadvertently violate 02:12
`the board's rules. 02:12
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:12
` So from what I've heard from you, 02:12
`you will revise these citations and provide the 02:12
`actual support and not refer to an external 02:12
`exhibit for your support or reasoning for claim 02:12
`construction. Is that right? 02:13
` MR. STRANG: Yes, Your Honor. We 02:13
`would appreciate that opportunity. 02:13
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:13
` We're also going to ask you to 02:13
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`Ex. 2001 - Page 13
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`Page 14
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`update the word count, and that will need to be 02:13
`an actual word count. 02:13
` MR. MOORE: Your Honor, this is Matt 02:13
`Moore. This is one question for clarification. 02:13
` Like if we make an argument that 02:13
`said the specification of somebody of ordinary 02:13
`skill in the art would mean X, we cite to the 02:13
`expert declaration, which shows the expert says 02:13
`that portion of the specification means X. 02:13
` We still should cite to the expert 02:13
`declaration that supports the proposition. 02:13
`Right? 02:13
` We're not meaning for it to add 02:13
`anything additional, but we're adding support 02:13
`from an expert to show what someone of ordinary 02:13
`skill in the art would think. 02:13
` Is that proper from your -- 02:13
` ADMINISTRATIVE PATENT JUDGE: I'm 02:13
`sorry. I'm addressing in this call the claim 02:13
`construction section. 02:13
` MR. MOORE: So I'm address- -- okay. 02:13
` Let's talk about the Strawn section 02:14
`on Page 14 -- 02:14
` ADMINISTRATIVE PATENT JUDGE: Yes. 02:14
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`Ex. 2001 - Page 14
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`Page 15
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` MR. MOORE: -- where it says: "The 02:14
`broadest reasonable construction," and it puts 02:14
`a definition and then we cite to the Strawn 02:14
`declaration. 02:14
` If Strawn is just saying "the 02:14
`broadest reasonable construction" and the basis 02:14
`for it, which is elaborated in more detail on 02:14
`Page 15 and it's just showing we have an expert 02:14
`to support that -- 02:14
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:14
`Let me short-circuit this. 02:14
` We're not going to get to analyze 02:14
`every paragraph where you cite the expert 02:14
`declaration. 02:14
` If you cite the expert declaration 02:14
`and you're using it to add arguments that are 02:14
`not in the petition, of course that's improper. 02:14
` If you're using it to support what 02:14
`you're already saying, then that's how you're 02:14
`using it. Okay? 02:14
` We're referring here specifically to 02:14
`incorporated arguments that should be in the 02:14
`petition if you want us to look at the claim 02:14
`construction and understand what is your 02:14
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`Ex. 2001 - Page 15
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`support for your claim construction. Okay? 02:14
`It's crucial that we have that right off the 02:14
`bat so that we know what are your arguments for 02:15
`that claim construction. And that's all we're 02:15
`addressing in this call. 02:15
` We're not going to get to 02:15
`dissertations on what is proper vis-à-vis 02:15
`obviousness and things like that. All right? 02:15
` MR. MOORE: Thank you, Your Honor. 02:15
` ADMINISTRATIVE PATENT JUDGE: I 02:15
`think we're done with the 1203 petition, unless 02:15
`there's anything else, Mr. Strang, you want to 02:15
`raise or discuss with us. 02:15
` MR. STRANG: No, thank you, Your 02:15
`Honor. 02:15
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:15
` With the 1211 and 1214, Mr. Glass, 02:15
`I'll give you the opportunity to discuss. 02:15
` MR. GLASS: Sure. Thank you, Your 02:15
`Honor. 02:15
` We're actually in a very similar -- 02:15
`we're very similarly situated to Jaguar in this 02:15
`case in terms of how we presented the 02:15
`arguments, although we did only construe -- we 02:15
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`Ex. 2001 - Page 16
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`construed fewer terms than they did. 02:15
` With respect -- well, first as a 02:15
`preliminary issue, with respect to the claim 02:15
`listing, we did include a claim listing. It is 02:16
`attached as an exhibit, Exhibit 1016 in each 02:16
`case. As we discuss corrections, I would of 02:16
`course be more than happy to incorporate that 02:16
`specifically into the petition. I apologize if 02:16
`that made it difficult for Your Honors to read 02:16
`the petition. 02:16
` With respect to the claim 02:16
`construction positions, we construe the term 02:16
`"device presence signal" similarly to how 02:16
`Jaguar did. We cited to the '421 ID as for the 02:16
`proposition of how the terms should be 02:16
`construed and the reasoning adopted by the 02:16
`board. 02:16
` Our rationale was similar. It was 02:16
`a -- the same term in this case, same patent. 02:16
`Two of the same judges, Your Honors Giannetti 02:16
`and Judge Lee, were involved in that decision. 02:16
`We felt that by adopting that position and that 02:16
`reasoning, we're akin to citing case law. 02:16
` There was of course no intent there 02:16
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`to subvert any word limits. It was 02:17
`construction we could live with. The reasoning 02:17
`was sound. And that's why we did it. 02:17
` With respect to the means plus 02:17
`function claim elements, again, we cited to an 02:17
`exhibit -- let me back up. 02:17
` We adopted a position by a PO that 02:17
`was in a District Court litigation. They 02:17
`proposed means plus function limitation -- 02:17
`constructions for these terms. 02:17
` We submitted Exhibit 1017 really to 02:17
`show -- and I get my claim construction section 02:17
`could be a little clearer on this point -- to 02:17
`show that this was a position they had taken. 02:17
` I quoted verbatim those claim 02:17
`construction positions, the function and the 02:17
`structure, verbatim in the argument section 02:17
`side by side with the claim limitation. 02:17
` So if you look in our argument 02:17
`section, I thought that -- in retrospect, 02:17
`maybe -- again, maybe I could have done this a 02:17
`little clearer. I felt that citing the 02:18
`constructions and the functions in the 02:18
`arguments section side by side with the prior 02:18
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`art would make it easier on the board. That 02:18
`may have made it a little more unclear. 02:18
` So again, we're not trying -- 02:18
`there's no intent to subvert word limitations. 02:18
`The constructions that we're proposing are word 02:18
`for word verbatim in our petition. 02:18
` And we're not relying on that 02:18
`exhibit. That exhibit was submitted simply to 02:18
`show that there was a proffer and proposed 02:18
`construction by a PO in the contemporaneous 02:18
`District Court litigation. 02:18
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:18
`I see. 02:18
` So to the extent that you have 02:18
`identified which means plus function terms -- 02:18
`because that section on means plus function 02:18
`claim elements doesn't say anything about which 02:18
`terms you contend are means plus function and 02:18
`what those constructions are, it led us to 02:18
`believe that you're relying on 1017 to identify 02:18
`those constructions, and that's entirely 02:19
`improper. 02:19
` So to the extent that you are 02:19
`relying on a specific term as a means plus 02:19
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`function term and you have a proposed 02:19
`construction for that, you may want to revise 02:19
`this in accordance with what we expect to see 02:19
`in that section, which is what is your position 02:19
`on claim construction. 02:19
` MR. GLASS: Yes. 02:19
` ADMINISTRATIVE PATENT JUDGE: And 02:19
`I'll leave that to you to figure that out. I'm 02:19
`not going to tell you how to rewrite your 02:19
`papers. But that is our concern. 02:19
` MR. GLASS: Understood, Your Honor. 02:19
`I understand. 02:19
` And I would suggest that we will 02:19
`take what's in our argument and put that -- cut 02:19
`and paste that to the claim construction 02:19
`section so it's clear what we are proposing. 02:19
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:19
` Let's see. Let me see if there are 02:19
`any additional issues here. 02:19
` We will -- we would of course want 02:19
`to have the revised petitions refiled as soon 02:20
`as possible. They would be corrected 02:20
`petitions. And we would like to have those -- 02:20
`how soon do you think you can make the 02:20
`
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`necessary corrections to avoid these 02:20
`incorporation issues? 02:20
` MR. GLASS: Is Wednesday too long to 02:20
`ask for, Your Honors? 02:20
` ADMINISTRATIVE PATENT JUDGE: No, 02:20
`it's -- I was going to give you a week, but 02:20
`Wednesday works for me as well. 02:20
` How about you, Mr. Strang? 02:20
` MR. STRANG: Petitioner Jaguar would 02:20
`request a week, Your Honor. 02:20
` ADMINISTRATIVE PATENT JUDGE: A 02:20
`week? 02:20
` MR. STRANG: Please, Your Honor. 02:20
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:20
` Well, everyone gets a week. Okay? 02:20
`So refiling in a week. 02:20
` We want word counts, actual word 02:20
`counts, for all of these petitions after this, 02:20
`and to make sure that there are no new 02:21
`arguments, no new evidence, no new anything. 02:21
`This is just going to be basically a 02:21
`reorganizing of the sections and taking 02:21
`citations that are being used to in any way 02:21
`incorporate by reference. 02:21
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` MR. GLASS: Your Honor, this is Jim 02:21
`Glass. 02:21
` I hate to ask this, but in the word 02:21
`count -- obviously, when you say "all word 02:21
`counts," I assume that means that we're going 02:21
`to go back and actually count the words in the 02:21
`figures. 02:21
` In our petition our figures are very 02:21
`word light. There's not a lot of words, but 02:21
`there are a ton of numerals. 02:21
` Are we expected to count the 02:21
`numerals that identify the different elements 02:21
`of the figures or just the actual words? 02:21
` ADMINISTRATIVE PATENT JUDGE: You 02:21
`know, I don't know how -- how does Word count 02:21
`words? That's a good question. Right? 02:21
` What we're concerned about is that 02:21
`the words are -- need to be counted, not so 02:22
`much the numbers or the periods or however 02:22
`Word's algorithms uses to make sure that it 02:22
`catches everything. 02:22
` But just use common sense here. 02:22
`We're not asking for something super highly 02:22
`hyper accurate or anything like that, but -- 02:22
`
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`you know what I'm saying. 02:22
` MR. GLASS: Understood, Your Honor. 02:22
` ADMINISTRATIVE PATENT JUDGE: Okay. 02:22
` Is there anything else in Petitions 02:22
`1211 and 1214 that you want to tell us about 02:22
`right now? 02:22
` MR. GLASS: Not from Daimler's 02:22
`point, Your Honor. 02:22
` MR. ROUSSEAU: Your Honor, this is 02:22
`counsel for Patent Owner. 02:22
` Will we get a -- 02:22
` ADMINISTRATIVE PATENT JUDGE: Yes. 02:22
`I was going to turn to you. 02:22
` So do you have anything to add? 02:22
` MR. ROUSSEAU: Yes. I mean, we 02:22
`have -- the general overarching concern -- and 02:22
`I'll pretext this with our POPRs aren't due 02:22
`yet, so in terms of our arguments, we're not 02:22
`going to preview that. 02:22
` But from Patent Owner's perspective, 02:23
`you know, these petitions were filed right at 02:23
`the deadline. You know, they're near bar. And 02:23
`from our perspective, if they don't comply with 02:23
`the rules and they're deficient, then that's 02:23
`
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`it. They shouldn't get a do over. They 02:23
`shouldn't get a chance to -- you know, what it 02:23
`sounds like is they're going to hav
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